CommentsOn 7-201X Comment M… · Web view4.6 Welding Standards. All welding, including pressure applications, shall conform to ANSI/AWS D1.1M. Structural Welding Code, Steel, or

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Comments on review of A92.7-201X Draft – Airline Ground Support Vehicle- Mounted Vertical Lift Devices Date: Document:

MemberName

Clause/sub-clause

Paragraph/Figure / Table

Type of comment (general /

technical /editorial)

Comment Proposed Language/Section Committee Observations

AWPT General General general This standard language closely follows A92.6 language and needs to examine language from A92.2 to ensure consistency for this equipment which is vehicle mounted. A92.2 committee should closely review to ensure both consistency and inclusion of all appropriate provision between the two standards.

The A92 main committee should closely review what is different in this standard from A92.2 and A92.6 to conclude if there is reason for a unique standard or if this equipment should be included in one of those two standards. Last, the review and comments of this standard demonstrates the need to make changes in the language of existing A92 standards and reaffirms the decision to move ahead with the development of new standards opposed to opening for review of the existing standards, which have the potential for significant changes and improvements.

No direct action other than we will take into consideration key elements of A92.6 that are pertinent: e.g. Installers

So noted.

Rick Heath General General General I have made this comment so many times it is getting silly. Why can’t anyone put page numbers and a publication date on draft

Done – SS 8.22.12

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documents? On the surface you can’t tell this one from the last one.

Rick Heath General General General I totally disagree with your position on the use of “AGSV vs. “Aerial Platform” but am giving up the argument in favor of moving forward.

Rick Heath General General General Having said that you have missed the removal of AGSV in a couple of places: Section 4.6 and Section 4.10.2.

Done – SS. 8.22.12

Rick Heath General General General You have missed a couple of places where you should have removed the year after the designation of a standard: Section 1.1.3(8); Section 2.4; and, Section 2.5 (4 places).

Done – SS 8.22.12

Rick Heath Entire document Technical This “final” draft was never balloted to the sub-committee and therefore should not have been sent to the consensus body for ballot.

ALLAgree. At this juncture we will consider as “lessons learned”. No action required.

Rick Heath Entire document Technical The sub-committee agreed to call the equipment covered by this standard “Airline Ground Support Vehicles” and to refer to them throughout the standard as AGSV or AGSVs. There are numerous places in the standard that incorrectly still use the term “Aerial Platform” or “Airline Ground Support Vehicle” or “vehicle” or “aerial device”.

1.1 second line: insert “(AGSV)” after “devices” and then correct the rest of the entire standard as described by performing multiple word searches.

See cover email comments.

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Rick Heath 1,1 Number of Vehicles

In Section 1.1 you list 11 types of vehicles and there are 11 vehicles shown in Figures 1 and 2 but there are two “Maintenance Lifts” and no “Potable Water Truck” shown in the figures.

Bob Backer will handle – Done SS 8.27.12

Richard Hoffelmeyer

1.1.1 Editorial “Figure” should be plural Change to “...Figures w and 2.”Lance-make change – Done SS 4.11.12

Bob Backer 1.1.1 (4) Technical Combine the Lavatory Service / Potable Water Trucks to correspond with the picture below

– Done SS 8.27.12

Rick Heath 1.1.1(6) Technical “Portable” is the wrong word. Change to “Potable”.Lance-make change– Done SS 4.11.12

Richard Hoffelmeyer

1.1.2 Technical Paragraph (1) refers to “the effective date”. I don’t see the effective date defined anywhere

Need to define effective dateLance- Add spaces between “ effective ___________as follows” for future date to be added– Done SS 4.11.12

Rick Heath 1.1.2(1) Editorial Poor structure. Second line change “will” to “shall”; add “produced” after “vehicles”; change “or” to “and”.

Lance-make change. Also change “remanufactured” to “manufactured” – Done SS 4.11.12

Rick Heath 1.1.3 Technical The subcommittee agreed to delete year of adoption in all referenced and related standards.

Add a sentence: “When these referenced standards are superseded by a revision, the revision shall apply.”

Lance-remove all dates as they apply to standards– Done SS 4.11.12

AWPT 1.1.3(2) editorial Should change date to current standard - --2001

ANSI A10.8-2001 Lance-remove all dates as they apply to standards– Done SS 4.11.12

AWPT 1.1.3(12) editorial Should change date to current standard

ANSI/NFPA 1901-2009 Lance-remove all dates as they apply to standards– Done SS 4.11.12

AWPT 1.2 purpose editorial The list of parties involved is inconsistent with current standards and limiting in scope and consistent with parties listed in (3) of purpose

..GUIDE FOR VERTICAL LIFT DEVICES...MANUFACTURERS, DEALERS, USERS, DESIGNERS, OWNERS, OPERATORS, LESSORS, LESSEES, AND BROKERS...

Lance-make change– Done SS 4.11.12

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Rick Heath 1.2(1) Section 1.2(1) I think you are making a mistake to infer that anything will “prevent” accidents. Plaintiff counsel will love the term “prevent”. I have offered this comment in the past and have been ignored so I will not push it further.

So noted

John Brewington

1.3 General No comment under heading “Application”.

Change “Application” to “Requirements” Add comments “The requirements of this standard shall be met or exceeded.”

Sara-make change

Committee- This was missed all together. In reviewing .2, .3, .5 & .6 latest stands I decided to follow .2 as it was straight forward and seemed to make good sense. – Done SS 4.23.12We adopted the language of A92.2, changed heading to “Requirements”. See Final Draft Attachment.

Rick Heath 2.1 Technical See comment 5. Delete year of adoption in all referenced and related standards. Lance-make change– Done SS 4.11.12

Rick Heath 2.1 Technical Wrong designation. ANSI/AWS D1.1 should be ANSI/AWS D1.1M Lance-make change– Done SS 4.11.12

Rick Heath 2.1 Technical Wrong designation. ANSI/AWS D1.2 should be ANSI/AWS D1.2M Lance-make change– Done SS 4.11.12

Rick Heath 2.1 Technical Missing reference, see 4.19.1(15). Add: ANSI/UL 201 Standard for Garage Equipment. Lance-make change– Done SS 4.11.12

Rick Heath 2.1 Technical Missing reference, see 4.19.1(15). Add: ANSI/UL 50 Enclosures for Electrical Equipment. Lance-make change– Done SS 4.11.12

Rick Heath 2.2 Technical See comment 1.1.3 Delete year of adoption in all referenced and related standards. Lance-make change– Done SS 4.11.12

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Rick Heath 2.2 Technical Missing reference Add: “Code of Federal Regulations (CFR) 1910, Subpart D, Walking and Working Surfaces.


Rick Heath 2.2 Technical Delete year of adoption in all referenced and related standards. Lance-make change– Done SS 4.11.12

AWPT 2.2(1) editorial this standard has been withdrawn and should not be listed

Delete Lance-make change– Done SS 4.11.12

Rick Heath 2.2(2) Technical Incomplete designation. Add title: “Selection and Use of Work Practices.” Lance-make change– Done SS 4.11.12

Rick Heath 2.3 Technical Delete year of adoption in all referenced and related standards. Lance-remove all dates as they apply to

standards– Done SS 4.11.12Rick Heath 2.3 Technical Missing reference. Add: ANSI/SIA 92.6 Self Propelled

Elevating Work platforms. Lance-make change– Done SS 4.11.12Daniel Moss 2.3 2nd & 3rd indents Editorial 6 is underlined Remove underline

Lance-make change– Done SS 4.11.12Rick Heath 2.3 A10.31 In Section 2.3: A10.31 should

appear ahead of A120.1. - Done SS 8.22.12

John Brewington

2.3 Related American National Standards

Delete the last sentence in the first paragraph. Rationale: The standards listed are for information only and future revisions of them do not “apply” to the draft standard.

We beat this one around and around and finally got rid of the dates all together.

We kept similar language in 2.1 and 2.2 for consistency.

Rick Heath 2.4 Technical Wrong designation. Delete “ANSI” from title of manual of responsibilities. It is not an ANSI document.


John Brewington

2.4 Referenced Scaffold Industry Association publications

Delete this section. Rationale: The Manual of Responsibilities is, by definition, a duplication of Sections 3, 5, 6, 7, 8, 9, 10, and 11 of the standard. This publication would

We feel that we need to maintain a “Manual of Responsibilities” until such time that the other standards deem differently.

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include all but approximately 16 of the current draft standard’s 44 pages. A more efficient way of communicating responsibilities, in my opinion, is to mandate ownership of a current copy of the standard by Dealers, Owners, Users, Lessors, Lessees, and Brokers. The responsibilities of Operators should be adequately covered in the Operator’s Manual furnished by the Manufacturer [see 4.21.1(4)]. This approach will remove the additional Manual of Responsibilities from being carrier on the aerial device where it is intended to make operators, and others having the responsibilities of operators, aware of their responsibilities. Most operators would be confused by the “standardize” language used in Sections 3, 5, 6, 7, 8, 9, 10, and 11 of the standard. They would be better served by materials added to the Operator’s Manual or contained in an illustrated and easy to read publication similar to the Safety Manual for Operating and Maintenance Personnel provided by the Association of Equipment Manufacturers (AEM) for aerial devices and other products. Acceptance of this change would effect: Definitions, 4.21.1(4), 5.2, 5.14(2), 6.2.1(5), 6.3.2, 6.18(2), 7.2.2, 8.2.2, 11.1(2), and 11.2(2).

We will entertain at next update

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Rick Heath 2.5 Technical Wrong designation. Delete “ANSI” from title of manual of responsibilities. These are not ANSI documents.


Rick Heath 3.0 Editorial Correct alignment. Move “Anchorage(s) to its own line.Lance-make change– Done SS 4.11.12

Rick Heath 3.0 Editorial Improper underline. Remove underline from definition of Rated Horizontal Force. Lance-make change– Done SS 4.11.12

John Brewington

3.0 Definition Lessee Editorial In the second sentence, delete the work “owner”. Rationale: By definition, an owner “has possession of an aerial device by virtue of proof of purchase”. A lessee, in my opinion, cannot “own” the aerial device they are leasing.

We feel a “Lessee” can own equipment and be a “Lessee” of an incremental piece of equipment. Hence, we have elected to keep it for this draft.

We will entertain it at the next update.

Daniel Moss Section 3 Definitions

Ductile mater Editorial Add space between 50.8 and mm Add spaceSara-make change – Done SS 4.23.12


Operator Editorial an should be removed Replace with "a"Lance-go back to “the” – Done SS 4.11.12


Rated horiz Editorial at the top rail is underlined Remove underlineLance-make change– Done SS 4.11.12


Training Editorial . is underlined Remove underlineLance-make change– Done SS 4.11.12


User Editorial Though this definition may appear in numerous documents, there is no reason to start the definition with "A".

Start sentence with: Person(s) or entity… Lance-make change– Done SS 4.11.12

Richard Hoffelmeyer

Section 3 Definitions

Airline Ground Support Vehicle (AGSV)

Editorial “Anchorage” definition part of “Airline Ground Support Vehicle (AGSV)” definition

Format properly.Lance-make change– Done SS 4.11.12

Richard Hoffelmeyer


Installer Technical I do not believe this is an appropriate definition of “Installer”. The manufacturer is “A person or entity that assemblies parts manufactured by another person or entity.”.

Use A92.2 definition.Lance-make change – Done SS 4.11.12

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Richard Hoffelmeyer


Outriggers Editorial “an” has been marked out. It needs to be added. Also, throughout the document the phrases “the aerial platform” and “the aerial platform” are used. Standardize on one or the other

See comment. I prefer “the aerial platform” Lance-make change. *Also remove

definition for “ASVG” all together. Wherever it was used replace with “the aerial platform” – Done SS 4.11.12

AWPT Section 3 Definitions

Anchorage(s) editorial Separate from AGSV definition – it is currently part of the same paragraph

Lance-remove “ASVG” definition, Bring “Anchorage(s)” definition in line with other definitions– Done SS 4.11.12


'equivalent entity'

editorial 'equivalent entity' not used in the standard

Delete this definition Lance-make change– Done SS 4.11.12


familiarization technical The standard must include all of the topics that an operator needs to be aware of regarding the use of a particular machine and the language needs to be consistent throughout the standard.

...regarding all control functions, operating characteristics, safety devices, placards and warnings

Sara- make change – Done SS 4.23.12

AWPT Section 3 definitions

installer editorial THIS DEFINITION is different from A92.2 and should look for consistency:

Installer. A person or entity who mounts an aerial device on a platform.



Jet Blast editorial Not in the standard Delete or add reference to term if needed Sara- We will keep “Jet Blast” definition.

See 4.9.3 comment. – Done SS 4.23.12


Passive editorial Not in the standard delete Lance-make change– Done SS 4.11.12


Steady-State Wind.

Editorial Not in the standard delete Sara-make change – Done SS 4.23.12

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Wind gust editorial Not in the standard delete Sara-we will keep “Wind Gust” definition. See 4.9.3 – Done SS 4.23.12


Platform height technical With language in the standard regarding various platform heights – ie travel height and platform height, and general use of working height vs platform height, it would be appropriate for the standard to define, as used in A92.2, rated platform height and use that term as needed in the standard

Rated Platform Height. The distance measured at maximum elevation from the bottom of the platform to the ground based on a chassis height of 40 inches.

No action- keep same as A92-6-2006


Maximum travel height

editorial See change to definition ‘platform height’

Change maximum platform height to ‘rated platform height No action-keep same as A92.6


Most Adverse conditions(2)

editorial See change to definition ‘platform height’

Change maximum platform height to ‘rated platform height No action-keep same as A92.6

AWPT 4.2.2 Chassis editorial Should look to be consistent consistent language with 92.2 language (6.2.1) VEHICLE SPECIFICATIONS.

The aerial device manufacturer shall provide to the installer the minimum values, as applicable, for the following characteristics of vehicles required to provide a stable and structurally sound vehicle for the aerial platform:

(4) The front….

Sara: after much deliberation as well as discussing this with A92.2 people, it makes sense as it relates to installers”.

Sara-make change – Done SS 6.3.12

Rick Heath 4.2.3 Properly align Section 4.2.3.All formatting will be done after approved

Rick Heath 4.14.2 Strength factor I applaud the change of the phrase “safety factor” to “strength factor” but you missed one place: Section 4.14.2.

Done SS 8.22.12

Rick Heath 4.17.2.1 In Section 4.17.2.1: remove the symbol that precedes the last sentence.

Done SS 8.22.12

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Rick Heath 4.19.1(1) In Section 4.19.1(1): properly align the three standards that are supposed to be listed here.

All formatting will be done after approved

Rick Heath 4.5 Editorial Poor structure. Change first sentence to read; “Each AGSV model shall sustain a uniformly distributed proof load equal to 1.50 times the rated work load throughout the range of travel while supported on a level surface.”

Lance-make change, however, replace AGVS with” the aerial platform’” as previously requested – Done SS 4.11.12

Rick Heath 4.6 Technical Too complicated and inaccurate. Change entire section to read: 4.6 Welding Standards. All welding, including pressure applications, shall conform to ANSI/AWS D1.1M. Structural Welding Code, Steel, or ANSI/AWS D1.2M, Structural Welding Code, Aluminium, or the equivalent welding codes in effect in the Country of AGSV manufacture. It is emphasized that these codes require qualification of the welding process to be employed and the certification of the personnel performing the welding under each welding process.


Rick Heath 4.7 Technical Use of the word “safety”. It is recommended that the term “safety” not be used as it infers that if the product is built to conform to the standard that it will be “safe”. This may become a legal issue in the event of a product failure.

Change “safety” to “strength” throughout the entire section, as in “Strength Factor” as opposed to “Safety Factor”.


Daniel Moss 4.7.3 Multiple places Editorial/technical Subscript values need to be in subscript font/style and equation values need to be in equation script. (see below).

Example: a2 should be a2 Lance-make change– Done SS 4.11.12

Daniel Moss 4.7.3 Multiple places Editorial/technical Equations/formulas should be shown using equations/formulas feature in MS word. Example:

a(a1+a2 ) f 1 f 2

Lance-make change – Done SS 4.11.12

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Daniel Moss 4.7.3 Where and in all places used

Editorial/technical Equations/formulas values should be shown using equations/formulas feature in MS word.

a2= stress due to rated work load


AWPT 4.8 controls Technical Need to add language on outrigger controls

NEW 4.8.5 Outrigger controls. When the aerial platform is equipped with outrigger controls, these controls shall be guarded to protect against unintentional operation, and shall return to neutral when released by the operator. The controls shall be located so that the operator can see the outrigger when operated. (language from A92.2)


Richard Hoffelmeyer

4.8.2 (3) Technical Add to the end of the sentence, “,if used to control any movement of the aerial platform”

Same as Paragraph 4.8.1 (4) – Done SS 4.11.12

Rick Heath 4.9.1 Technical Unintended consequence.In the second sentence insert the word “sample” after Each to clarify that it is not intended to test every production unit. Sara-make change – Done SS 4.23.12

Rick Heath 4.9.3(1) Editorial Poor form.Remove the term “ASGV”. – Done SS 4.11.12

Daniel Moss 4.9.3 Multiple places Editorial Use of exponents. Values need to be corrected. Example: ft2 should be ft2– Done SS

4.11.12Daniel Moss 4.9.3 Multiple places Editorial Correct use of abbreviations.

Example: mi/hr should be mph and – Done SS 4.11.12km/hr should be kph.

Daniel Moss 4.9.3 Multiple places Editorial/technical Equations/formulas should be shown using equations/formulas feature in MS word.

Example: F=cd (0.00252) V2

– Done SS 4.11.12

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Daniel Moss 4.9.3 Where and in all places used

Editorial/technical Equations/formulas values should be shown using equations/formulas feature in MS word.

F = unit force in ft/lb2– Done SS 4.11.12

John Mlaker 4.9.3 Technical/Editorial Add topic “Wind Loading”

Change ft2 to ft2

Change F to Fw

Change cd to Cd

Change V2 to V2

– Done SS 4.11.12

Richard Hoffelmeyer

4.9.3 Technical/Editorial “V2” should be “V²” two places“lb/ft2” should be lb/ft² one place See Comment Lance-make change including all the

above that I could not comment in that are “green” – Done SS 4.11.12

Bob Backer 4.9.3 Technical/Editorial Include “Jet Blast and “Wind Gust” in the text so as to correspond to the definition After “wind” add “gust and jet

blast load requirements”


Rick Heath 4.10 Technical Clarification of intent.

Second sentence: add the words “each wheel” after “then”; replace “definition “ with “description”; insert “while” after “speed”; replace “with any axle”; with “both”.


Rick Heath 4.10 Test Fixture Technical Clarification of intent.

First sentence: change “defined” to “described”. Third sentence: replace “corners shall be symmetrically cut” with “two edges shall be bevelled”; delete the word “longitudinal”; replace “providing “


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with “leaving”. Fourth sentence: correct the spelling of “be”.

Daniel Moss 4.10 Test fixture Editorial Use of underline and numbering

Remove underline and consider numbering as 4.10.1 or 4.10.2 if the clauses above could be 4.10.1 General.


Daniel Moss 4.10 Test fixture Editorial Use of "X"

Consider using "x" as it would be more appropriate.


Richard Hoffelmeyer

4.10 “Test Fixture” Editorial “The test fixture shall b secured...” should read “The test fixture shall be secured...” Typo See Comment


John Mlaker 4.10 Editorial The last sentence of Test Fixture need to have the “b” changed to “be”.

Test Fixture The test fixture is defined as a device used to simulate obstacles that may be encountered on an airport ramp (e.g. wheel chocks, storm drains, fuel pit lids, snow and ice ruts, etc.). The test fixture shall be made out of wood measuring 10.2 cm (4 in) high X 15.2 cm (6 in) wide X 60.96 cm (24 in) long. The top corners shall be symmetrically cut at 45º angles along the longitudinal length of the member providing a top flat surface measuring 5.1 cm (2 in) in width. The test fixture shall be secured in such a manner that prevents sliding or overturning as the AGSV is driven over it during dynamic load testing.


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Rick Heath 4.11.2 Editorial Poor Form Last sentence: replace “calculations” with “design”; replace “worst” with “most unfavourable”.


Richard Hoffelmeyer

4.11.2 Editorial The second line reads, “...requirements of the Standard...” should read “...requirements of this standard...”

Change the to this and remove capitalization of the word standard Lance-make change– Done SS 4.11.12

Rick Heath 4.12 Technical Clarification of intent. First paragraph, second paragraph and third paragraph: insert “maximum” before “operating.


Rick Heath 4.13.1 Technical Use of the word “safety”. It is recommended that the term “safety” not be used as it infers that if the product is built to conform to the standard that it will be “safe”. This may become a legal issue in the event of a product failure.

Change “safety” to “strength”.

Daniel Moss 4.14 Editorial No "." needed. Remove "." from 4.14 title.Lance-make change– Done SS 4.11.12

Rick Heath 4.14.2 Technical Use of the word “safety”. It is recommended that the term “safety” not be used as it infers that if the product is built to conform to the standard that it will be “safe”. This may become a legal issue in the event of a product failure.

Change “safety” to “strength”.

Rick Heath 4.15 Technical Poor form. Replace “or” with “and” and delete “or both”. Lance-make change– Done SS 4.11.12

Daniel Moss 4.16 Editorial No "." needed. Remove "." from 4.16 title.Lance-make change– Done SS 4.11.12

Rick Heath 4.16.2 Technical Clarification of intent. Replace “a” with “an audible”.Lance-make change– Done SS 4.11.12

Rick Heath 4.17.1 Technical Clarification of intent. Replace “cables” with “wire ropes”.Lance-make change– Done SS 4.11.12

Daniel Moss 4.17.1 1st and 2nd sent Editorial Spacing needed between .46 and m and extra period and comma.

Change to: Platform width shall not be less than 18 inches (0.46 m), unless justifiable due to unique application. The platform floor…


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Daniel Moss 4.17.1 2nd para, 2nd sent Editorial/general Term "Manway" is not defined. Either define or choose another term.Lance-make change– Not sure which term to use. Sara-remove “Manway fences or” staring with “Gates” – Done SS 4.23.12

Daniel Moss 4.17.1 2nd para, 2nd sent editorial Comma is not needed between outside and unless.

Remove CommaLance-make change– Done SS 4.11.12

Daniel Moss 4.17.1 2nd para, 3rd sent editorial Period missing at end of sentence. Add period after event.Lance-make change– Done SS 4.11.12

Daniel Moss 4.17.1 Last sent editorial/general Though this language may be used in other standards, the use of "five eights" then (5/8) is not correct.

Use .625 followed by metric equivalent.

Richard Hoffelmeyer

4.17.1 Editorial The first sentence should read, “Platform width shall not be less than 18 inches (0.46m), unless justifiable due to unique application.”

Delete the period “.” After (0.46) and replace the comma “,” with a period “.” at the end of he sentence.


Richard Hoffelmeyer

4.17.1 Second paragraph

General/Technical The terms “protective system” and protective devices” are used in this paragraph

Neither of these terms are defined in the definitions section and the meaning to me is not clear. Need to reword or define the terms.

Sara- Replace “protective system” with “platform” Replace “protective devices” with “guardrails” – Done SS 4.23.12

John Brewington

4.17.1 The referenced sections of 29 CFR 1910 are not included in 2.2 Other Referenced Standards. Editorial Change.

We agree.

Sara: make the change if not already done so.

– Done SS 8.8.12Daniel Moss 4.17.2 Multiple places Editorial Spacing needed between values. Example: 42 in (1.07 m)

Lance-make change– Done SS 4.11.12Daniel Moss 4.17.2 Multiple places editorial/technical Inconsistent conversions. Sometimes

the imperial is before the metric and vice-versa.

Example: 3 inches (76 cm) should be 76 cm (3 in). Lance-make change All are consistent, but

they are all imperial before metric throughout the document. I can change them all if needed. Sara-keep as is – Done SS 4.23.12

Rick Heath 4.17.2.3.3 Technical Clarification of intent. Replace “personal protective” with “fall prevention”. Lance-make change – Done SS 4.11.12

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Rick Heath 4.17.2.4 Technical Clarification of intent. Replace “reaching ultimate strength” with “fracture”. Lance-make change– Done SS 4.11.12

Richard Hoffelmeyer

4.17.3 Technical The last sentence seems a bit contradictory to the very last sentence of Paragraph 4.17.1. This would seem to allow a 5/8” diameter ball to roll out of the opening and fall.

Seems contradictory? Maybe I am misreading. 5/8” dia. ball is referenced so as not to be

any larger to maximize the opening in floor

Sara-Do not change – Done SS 6.3.12AWPT 4.17.3 toe boards technical There is a concentrated load

test requirement for GR and a similar design load should be required for toe board. This allows for minimum standard of the material to be used. Also suggest common language for toe boards as used in A92.2

The platform shall include toeboards or kickplates on all sides designed to withstand XXXX pounds of force in any direction. The minimum height shall be 4 inches.

Sara-Do not change – Done SS 6.3.12

AWPT 4.17.3 toe boards technical The option to omit toeboards at the access opening creates a potential hazard for falling material. This should not be allowed and the inclusion of the toebaord at the entrance should address any potential tripping hazard in the design of the entrance gate

Delete Toeboards may be omitted at the access opening(s).

No action-keep same as A92-6-2006

AWPT 4.18(4) Anchorages The location ‘to minimize lanyard slack’ has no meaning as the length of the lanyard is not defined in the standard. The location must provide that a restraint system can be achieved and that would require the anchorage to be located low in the platform

The anchorage must be located at a height no higher than the height of the mid rail.

Sara-Make this change – Done SS 4.23.12

Rick Heath 4.19.1(1) Editorial Poor form. Delete “(add dates)”.Lance-make change – Done SS 4.11.12

John Brewington

4.19.1 Add ambient temperature range in which the aerial device is designed to operate. Comment:

Rationale: Relays critical information to persons selecting and operating aerial devices.

We agree.

Sara: add “Ambient temperature range for which the aerial platform is

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This important information is missing from the standard.

designed” as an incremental item to this section..

– Done SS 8.8.12 AWPT 4.19.1(4) & (5) Manufacturer

information editorial See change to definition ‘platform

height’Change maximum platform height to ‘rated platform height No action-keep same as A92.6

Daniel Moss 4.19.1 (7) editorial/technical Capitalization and use of terms Operating Manual should be operator's manual. Lance-make change – Done SS 4.11.12

Richard Hoffelmeyer

4.19.1 (10) Technical/Editorial ANSI/SIA A92.2-2001 is not current Should be ANSI/SIA A92.2-2009. Unless it is intended to be limited to the 2001 version?

Lance-remove date for consistency with above similar actions – Done SS 4.11.12

AWPT 4.19 Manufacturer information

technical Maximum allowable wind speed is a requirement for safe use that must be added

ADD (17) Maximum allowable wind speed Sara-Do not make this change – Done

SS 4.23.12

Bob Backer 4.19 Manufacturer Information

Technical Include information that is in A92.5 Add (17) “A statement that only properly trained and authorized personnel shall be permitted to operate the aerial platform”


AWPT 4.19.2 Platform work loads.

technical Rated side loads are included in A92.6 and are required for safe use and must be added

The rated work load, side load, load distribution and number of occupants, where applicable, shall.....


John Brewington

4.19.10 (10) Update referenced A92.2 standard by changing to revision 2009. Editorial Change.

We elected to remove all dates

AWPT NEW Manufacturer safety Bulletins

technical The standard has direction for dealers and owners to comply with manufacturer safety bulletins, but do not define them or make reference to manufacturers providing them

ADD new sectionManufacturer Safety BulletinsManufacturers shall develop and ensure deliver to all registered owners of safety related bulletins that may arise after the manufacture of any AWP

Sara: after much deliberation I agree that this is a relevant item. Add new section.

Sara-make change– Done SS 6.3.12 *Made it 4.19.3 & changed AWP to aerial work platform

Daniel Moss 4.21.1 editorial/technical Use of terms. Operating Manual should be operator's manual. Lance-make change – Done SS 4.11.12

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Sara- Replace AGSV” with aerial platform”. – Done SS 4.23.12

Daniel Moss 4.22 editorial Numbering error. 4.2 should be 4.22.Lance-make change – Done SS 4.11.12

AWPT 4.23 Training & Training materials

technical Operator training is one of the most important aspects of AWP safe use must be specifically mentioned as one of the parties manufacturers must support in their training materials. Safe use by operators is a critical training component for all AWP use and operators must be added to the list of parties that manufactures must support in their training materials and should be specifically listedConsidering that the manufacturer operation manual is for operators, it seems logical that they be included in the listing of parties

Manufacturers (remanufacturers) shall develop and offer training materials that will aid dealers, owners , users and operators in meeting their responsibilities as outlined in this standard.

Sara-make change - – Done SS 4.23.12

AWPT 4.24 Manufacturer as dealer

technical A manufacturer may also be an owner, user, etc and should incorporate all the responsibilities when acting as such.

This same language can be applied to all other roles in the standard.

When a manufacturer acts as a dealer, owner, user or operator, the manufacturer shall assume the appropriate responsibilities as outline in this standard for that role.


Daniel Moss 5 Multiple places where there are lists

Use of periods. Lists should be only have periods when they are complete sentences. A colon should be used for lists.

Use colons instead of periods when not complete sentences. Lance-make change– Do we need semi

colons after each list item? I can make changes if needed

Sara-make changes as applicable

AWPT 5 Responsibilities of a dealer

general Should this section be for dealers and installers, as defined in A92.2?

Sara: after much deliberation as well as discussing this with A92.2 people, it

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If yes, add ..or installer... after each reference to dealer in this section.

Also, IF installer is acceptable addition, should incorporate additional language from A92.2: 7.2 Vehicle specifications7.3 Vehicle Weight distribution 7.5 Installation

makes sense as it relates to installers”.

Sara-make change – Done SS 6.3.12 *also added the A92.2 info as 5.15, 5.16 and 5.17 – Can move them if needed

AWPT 5.2.1 Machine manualsLast sentence

technical It makes no sense that ops and maintenance manuals MUST be provided, and upon sale - repair and parts manuals only SHOULD be provided. Repair is an essential safety issue and upon sale MUST also provide these manuals

In addition, repair and parts manuals MUST be provided with each sale delivery.


AWPT 5.3 Pre-delivery preparation

technical This process is equally technical to the requirements of frequent and annual inspections and should incorporate similar language to be performed by a person qualified as a mechanic.

Ideally, we should separate our maintenance and service as different task, one to be accomplished by persons skilled as a mechanic and identify which task are maintenance and which are service, as defined in the standard

Add.... Aerial platforms shall be inspected, serviced and to the manufacturer's requirements prior to each delivery by sale, lease or rental. The work shall be performed by adjusted by a person qualified as a mechanic on the specific type of aerial platform or one having similar operating characteristics.

Sara-Add “The work shall be performed by a person qualified as a mechanic on the specific type of aerial platform or one having similar operating characteristics”. – Done SS 4.23.12

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AWPT 5.3 Pre-delivery preparation

editorial As this incorporates inspection, service and potentially repair , this may be better placed under section 5.4

Move to section 5.4 Sara-do not change – Done SS 4.23.12

AWPT 5.7 training technical The standard has a definition for maintenance and repair, yet this section refers to maintenance, but not repair.

The standard should be clear that training must be offer for both maintenance and repair, especially considering that owners of equipment need this training

... comply with requirements set forth in this standard regarding the inspection, maintenance, repair, use, application, and operation of the aerial platform.


AWPT 5.7 Training – technical Many dealers may elect to outsource their training to other parties. Some small dealers may not have the staff, qualified persons, etc in house to provide this service. The requirement should add language that is used with owners to allow for outsourcing, such as online training from the manufacturer.

The dealer shall, upon the request of the owner, user or operator, offer to do training or advise where training may reasonably be obtained to facilitate their complying with requirements set forth in this standard regarding the inspection, maintenance, use, application, and operation of the aerial platform.


Richard Hoffelmeyer

5.8 Technical This is too restrictive and unduly burdensome to require a Dealer to familiarize with every delivery

There needs to be an out for provisions for other arrangements to be made, such as “familiarization records on file” , documentation that designated person performs own company familiarization with users or something like that.

Sara-after shall remove “have the responsibility with” and replace after shall “offer familiarization to” – Done SS 4.23.12

AWPT 5.8(3) Editorial and technical

We need to have consistent language from one section of the standard to another on the same topic and include all of the issues that must be

(3) Review all control functions, operating characteristics, placards

Sara-make change– Done SS 4.23.12

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presented at point of familiarization and warnings with the operator or person(s) designated by the user.

AWPT 5.9 technical See comment for 4.24 When a dealer acts as an owner, user or operator, the dealer shall assume the appropriate responsibilities as outline in this standard for that role.


AWPT 5.11.1(8) Record retention technical This section is record retention and there is no provision in the standard that removes the responsibility to deliver familiarization based on the criteria listed here. It is a point of confusion and does not add value.

delete wording after ..upon each delivery>" Sara-make change – Done SS 4.23.12

AWPT 5.11.1 Record retention technical The standard defines maintenance and repairs and language and refers to both maintenance and repairs in various clauses as separate task. Dealers must also retain maintenance records

ADD(10) records of all maintenance performed


AWPT 5.11.2 Proof of training editorial Operators may be trained other than with a dealer and the wording should clearly state that this responsibility is in place only when the dealer provides the training.

add language at the beginning…“When a dealer provides operator training, they SHALL provide trainees who successfully ..."


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AWPT 5.11.3 (2) Record dissemination

technical See comment 5.11.1 Add language to include maintenance

To the owner of the aerial platform, a copy of repairs and maintenance accomplished.


Richard Hoffelmeyer

5.12 Editorial Change “this Standard” to “this standard”

Remove capitalization of “standard”Lance-make change – Done SS 4.11.12

AWPT 5.13 Manufacturer safety bulletins

general Manufacturer safety bulletins are sent to owners, not dealers. Language should reflect this

This language is consistent with the addition of ‘user’ with owners for the section

as received from the manufacturer (remanufacturer), or owner.

Daniel Moss 6 Multiple places where there are lists

editorial Use of periods. Lists should be only have periods when they are complete sentences. A colon should be used for lists.

Use colons instead of periods when not complete sentences. Lance-make change– Done SS 4.11.12

John Brewington

6.2.1 (3) Delete this paragraph Rationale: Section 5.14(4) requires this be done by the entity selling the aerial device. Duplicate compliance is not needed by seller and buyer, in my opinion

We do not disagree with your opinion as much as we want to stay consistent with A92.6 as our basis document. We have elected to keep it for this draft.


AWPT 6.3.1 Machine manuals

technical See comments for 5.2.1Sara-make same change as 5.2.1 – Done SS 4.23.12

AWPT 6.4.1 & 6.24.2 technical suggest changing the word ‘arrange’ to “ensure’ The term ensure is consistent within the standard, while ‘arrange’ is only used with

The owner of an aerial platform shall ensure that .....


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owners, and does not need to be different or imply something different, like outsourcing. 6.6 & 6.7 use the term ensure. We need to be consistent with language unless there is good reason otherwise.

AWPT 6.4.3 new technical We need to consistently state that the manufacturer’s recommendations must be followed.

ADDRepairs accomplished to correct malfunctions and problems shall be in accordance with the manufacturer’s (remanufacturer’s) manuals and instructions.


AWPT 6.4.3 new technical Repairs must be accomplished by a person qualified as a mechanic. We need to distinguish that maintenance is different than repair and the skills required are different than that of an operator.

ADDThe repairs shall be made by a person qualified as a mechanic on the specific type of aerial platform or one having similar design characteristics.


John Mlaker 6.6 Editorial Add a section 6.6.1 to separate the first three item numbered topics from the next eight item numbered topics. 6.6 Frequent inspection. The owner of

an aerial platform shall ensure that a frequent inspection is performed in accordance with the manufacture’s (remanufacturer’s) instructions, for the


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aerial platform:(1) That was purchased used. This

inspection shall be accomplished unless it is determined that the frequent and annual inspections are current;

(2) That has been in service for three (3) months or 150 hours, whichever comes first;

(3) That has been out of service for a period longer than three months.

John Mlaker 6.6.1 Editorial See my above comments on 6.6 6.6.1 The inspection shall be made by a person qualified as a mechanic on the specific type of aerial platform or one having similar design characteristics. The inspection shall be in accordance with items specified by the manufacturer (remanufacturer) for a frequent inspection and shall include, but not be limited to the following:(1) All functions and their controls for

speed(s) smoothness, and limits of motion;

(2) Lower controls including the provisions for overriding of upper controls

(3) All chain and cable mechanisms for adjustment and worn or damaged parts;


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(4) All emergency and safety devices;(5) Lubrication of all moving parts,

inspection of filter element(s), hydraulic oil, engine oil, and coolant as specified by the manufacturer;

(6) Visual inspection of structural components and other critical components such as fasteners, pins, shafts and locking devices;

(7) Placard, warnings and control markings;

(8) Additional items specified by the manufacturer.

The owner shall not place the aerial platform into service until all malfunctions and problems have been corrected.

AWPT 6.7 new technical 7.3.1 Require a user to ensure that an annual inspection is completed - who will he be able to do this unless the owners provides this or some other notification?

Add at end…The owner shall place a decal in the area of the ground controls that states the date of the last annual inspection.


AWPT 6.8 Title technical The standard define maintenance and repair as different task – and needs to address both as separate task in the standard

Maintenance and Repair safety precautions Sara-make change – Done SS 4.23.12

AWPT 6.10 Title technical See comment for 6.8 Maintenance and Repair trainingSara-make change – Done SS 4.23.12

Richard Hoffelmeyer

6.12 Technical This is too restrictive and unduly burdensome to require an Owner to familiarize with every delivery

There needs to be an out for provisions for other arrangements to be made, such as “familiarization records on file” , documentation that designated person performs own company familiarization with users or something like that.

Sara-after shall remove “have the responsibility with” and replace after shall “offer familiarization to” – Done SS 4.23.12

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AWPT 6.12(3) Editorial and technical

We need to have consistent language from one section of the standard to another on the same topic and include all of the issues that must be presented at point of familiarization

(3) Review all control functions, operating characteristics, placards and warnings with the operator or person(s) designated by the user.


AWPT 6.13 Entire section technical See comments 4.24 When an owner acts as a dealer, user or operator, the owner shall assume the appropriate responsibilities as outline in this standard for that role.


AWPT 6.14 Title and language

technical An owner may sell to another owner and must include owners in their required assistance

Assistance to others.If an owner is unable to answer an owners, user's or operator's question(s) relating to.......


AWPT 6.15.1 new technical Date of training is required in 5.11.1(7) and should be added here for consistency

(7) date of trainingChange following numbers accordingly


John Brewington

6.18 Add a paragraph – “Shall, within 60 days of the sale, notify the

manufacturer (remanufacturer) or its successor (if existing) of the

sale, providing the full name and address of the purchaser”.

Rationale: The owner should be responsible for notifying the

manufacturer 1) that the aerial device has been sold, and 2) who

now owns the aerial device.

Add a paragraph – “Shall, within 60 days of the sale, notify the manufacturer (remanufacturer) or its successor (if existing) of the sale, providing the full name and address of the purchaser”. Rationale: The owner should be responsible for notifying the manufacturer 1) that the aerial device has been sold, and 2) who now owns the aerial device.

We agree.

Sara: Add John’s comment to this section.

– Done SS 8.8.12

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AWPT 6.18(3) technical It is illogical that the standard mandates a copy of the manual of responsibilities be provided to an owner but only recommend that a copy of the repair and parts manuals be provided. The standard requires that maintenance and repair follow the manufacturer recommendation and that can only occur if the manuals are provided. Must change to SHALL, not should.

(3) Shall provide repair and parts manuals to the new owner.


AWPT 7.3 1st sentence editorial It is the operator and others working for the user who will perform that function and have the same language for the operator may be confusing. Clearly stating that it is the users responsibility to ensure that this is accomplished, similar to language in the last sentence is important and those he assigns are qualified to perform the task.

Users shall ensure that the aerial platform is inspected and maintain by a qualified person as required to ensure proper operation......


AWPT 7.3 Last sentence Technical editorial The clarity of the qualification for repair, it should be stated as in others sections that the person must be qualified as a mechanic on the specific type of aerial platform – not just the general mindset that a mechanic is a mechanic. There are unique safety devices and machine characteristics that make the individual qualified and the more clear the language in the standard, the more likely compliance will occur

....Repairs shall be made by a person qualified as a mechanic on the specific type of aerial platform or one having similar characteristics. The repairs shall be in conformance with the manufacturer's recommendations.


AWPT 7.3.1 and 7.3.2 Technical and editorial

It is the owner’s responsibility to ensure that frequent and annual inspections are conducted. The user must only ensure that the machines being operated beyond the dates of the last inspections They also have no way to validate that the inspections

Users shall ensure that aerial platform being operated have not exceeded the date required for the next frequent


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were conducted in accordance with the standard . To accomplish this requirement, the owner conducting the inspections must place a decal on the machine to identify when the next inspection is due

AWPT 7.3.3 Prestart inspection

technical The prestart inspection is a task for the operator – the user must ensure that it is done and must state so in the standard

The User shall ensure that a qualified person or the operator authorized to operate the AWP, before use each day or at the beginning of each shift, shall perform a visual inspection and functional test including but not limited to the following:


Sara-Change AWP to aerial platform – Done SS 4.23.12

AWPT 7.4 B NEW general The reference to replacement parts only addresses what is already on the machine. Too often a user will add a new device or component to the machine that is not addressed in part replacement and may not be understood as a modification. Examples are second tier manufacturer components – tire socks, platform weather protection, tool holders – manufactured expressly for AWPs - users will not think of this as a modification – especially as marketed for use with AWPs. Providing some language will be of value

Adding components or devices to an AWP. Adding any component or devices to an AWP that was not supplied by the original AWP manufacturer is not allowed without the prior written approval of the manufacturer..

May have some validity, but will be considered at next re-write.

Sara-Do not change – Done SS 6.3.12

AWPT 7.5 Title technical See comment for 6.8 Maintenance and Repair trainingSara-make change – Done SS 4.23.12

AWPT 7.5 technical Repair and maintenance are different and need to be listed separately

The user shall ensure only qualified personnel inspect, repair and maintain the aerial

Sara- make change. However put “maintain” ahead of “repair” for consistency with new title. – Done SS

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platform....... 4.23.12Daniel Moss 7.6 Multiple places

where there are lists

Editorial Capitalization errors. Lists that complete an opening statement like should not start with first word capitalized. Each clause in the list completes the opening statement.

Example: …the user shall ensure that the person has been:(1) trained before being assigned to operate the aerial platform.


AWPT 7.6 editorial Add language to refer to section in the standard that they must comply with

change to read :......shall ensure personnel, prior to authorization to operate, has:(1) Successfully completed general operator training as defined in section 8.5 of this standard (2) received familiarization on the aerial platform to be operated(3) been made aware of all operator responsibilities as outlined in section 8 of this standard(4) Successfully completed retraining, if necessary, based on...


AWPT 7.7 1st sentence editorial to be consistent with language in the standard, change ‘permit” to ‘authorize’

The user shall authorize only properly...


AWPT 7.7(3) Technical Operating characteristics are critical to the function of the awp should be included in familiarization

(3) understands all control functions, operating characteristics, placards and warnings.


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AWPT 7.8 1st sentence technical The worksite inspection is a task for the operator – the user must ensure that it is done and must state so in the standard

The User shall ensure that a qualified person or the operator authorized to operate the AWP, before use each day or at the beginning of each shift, shall check the area in which the aerial platform is to be used for possible hazards such as, but not limited to:

Sara-make change. Change “AWP “to “aerial platform”. – Done SS 4.23.12

AWPT 7.10 A New section General / editorial The existing title does not clearly designate the specific responsibility for users regarding supervision and should be made into it’s own section. This will add clarity to the responsibilities of the user above the ‘operator warnings and instructions

NEW SECTION

User supervision.The user shall direct personnel operating the aerial platform to be in compliance with the provisions set forth in section 8 of this standard. The user shall monitor their performance and supervise their work to ensure the use, application and operation of the aerial platform is in conformance with the provisions set forth in this standard, warn personnel of potential hazards, provide means to protect against identified hazards, and explain the potential consequences of not following proper operating guidelines.

Sara-do not change – Done SS 4.23.12

AWPT 7.10 B editorial Following new section 7.10B, Operator warnings and Instructions.The user shall direct all personnel


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authorized to operate AWPs and those authorized to supervise the operators be aware of and compliant with the instructions and guidelines regarding proper guidelines. Instructions and guidelines regarding proper operation shall include, but......

AWPT 7.10(1) editorial The standard must clearly add language that use of PFPE must be in compliance with the OSHA regulations and ANSI Z359 standards.

Add new sentence to end:The selection, use, inspection, and training for all personal fall protection used with the AWP must be compliant with the OSHA fall protection regulations and ANSI Z359 standards.


Sara-change “AWP” “aerial platform” – Done SS 4.23.12

Richard Hoffelmeyer

7.10.3 Technical I do not understand how “oscillating axles” can be considered a “stability enhancing means”?

Delete “oscillating axles” from sentenceLance-make change– Done SS 4.11.12

Bob Backer 7.10(10) EditorialSara-change “AGSV’s” to “aerial platforms” – Done SS 4.23.12

AWPT 7.10(11) general The language is not specific with addressing locking out machine with a safety related problem.

Add new sentence at end.Any machine reported to have a safety related problem must be tagged out, isolated and removed from service until properly repaired by a qualified person.


Rick Heath 7.10(27) Editorial Poor form. Delete “/basket”.Lance-make change– Done SS 4.11.12

AWPT 7.10(35) editorial Adequate ground support is a critical issue with machine stability. It may be of value to add language that incorporates ‘when travelling and stationary’ to have consideration for support under the transport route in addition to the specific site of work

The user shall ensure the support surface under the AWP along the travelling part and actual work site is adequate for the aerial platform and the load carried.


AWPT 7.11 General and technical

See comment for 4.24 When a user acts as a dealer, owner, or operator, the user shall assume the appropriate responsibilities as outline in this standard for that role.


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Daniel Moss 7.13.1 3rd indent Editorial This clause does not fit with the subject statement. It seems to stand alone.

Make stand alone clause.Lance-make change– Done SS 4.11.12

Daniel Moss 7.13.1 4th indent Editorial This clause does not fit with the subject statement. It seems to stand alone.

Make stand alone clause.Lance-make change– Done SS 4.11.12

AWPT 7.13.1 general Ensure language is consistent with other parties for this topic So noted

Rick Heath 7.13.1.1 & 7.13.1.2

Remove Highlight

In Sections 7.13.1.1 and Section 7.13.1.2 remove the yellow highlight.

Done SS 8.22.12

AWPT Section 8 General/editorial Make changes to this section to be consistent with language changes to topics in earlier section, if agreed to

So noted

Daniel Moss 8.6 Multiple places where there are lists

editorial Capitalization errors. Lists that complete an opening statement like should not start with first word capitalized. Each clause in the list completes the opening statement.

Example: Before operating, the operator shall:(1) read and understand…




Example: Before each elevating of the platform, the operator shall:(1) outriggers, stabilizers, extendable axles…


Rick Heath 8.10(37) Editorial Poor form. Delete “/basket”.Lance-make change– Done SS 4.11.12

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John Brewington

10.3 Delete this section. Rationale: A lessee by definition is “a person or entity to which an aerial platform is provided by lease, rental, loan, or other arrangements”. An owner “has possession of an aerial device by virtue of proof of purchase”. You cannot be both for the same aerial device, in my opinion.

We feel a “Lessee” can own equipment and be a “Lessee” of an incremental piece of equipment. Hence, we have elected to keep it for this draft.




Example: The broker shall:(1) upon delivery, ensure the operating…




Example: …the broker shall:(1) upon delivery, ensure the operating…


Rick Heath Figure 1 and 2 Technical Eliminate redundancy. Both figures depict a “maintenance lift”, select one or the other. So noted

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Documents

CommentsOn 7-201X Comment M… · Web view4.6 Welding Standards. All welding, including pressure applications, shall conform to ANSI/AWS D1.1M. Structural Welding Code, Steel, or