Comment from Casto, Philip; HUB

Requirements for operator training, vehicle inspection, acceptable conditions for use, and the use of fall protection are not well defined for aerial work platforms. Several state plans make a more detailed attempt to identify whats requried of employers and employees. The Federal regulation should clarify this. The MIOSHA construction standards published that its' Aerial Work Platforms standard was one of the states 10 most cited standards in 2011. The potential for deaths and serious injuries associated with the use of this type of equipment is high and there have been several highly visible deaths from this equipment, including the death of a University of Notre Dame student while filming from an aerial work platform. It seems that the state plans have identifed and addresed this hazard, why hasn't Federal OSHA?