Most everyone working in equipment rental has heard that ANSI A92 aerial work platform standards impose new requirements on businesses that rent mobile elevating work platforms (MEWPs). Significantly fewer, however, have a solid handle on what these standards mean for their daily operations, their employees, and their customers. This article breaks down the key compliance obligations for rental houses under the updated ANSI A92 framework and offers practical guidance for meeting them.
Understanding the Dual Role of Rental Houses Under ANSI A92
The first and most important concept rental houses must grasp is how the ANSI A92 standards classify them. Under the updated language, a rental house is simultaneously considered a “dealer” and a “user.” This dual classification carries distinct responsibilities that affect every aspect of MEWP operations, from equipment delivery to employee training.
Dealer Responsibilities
As a dealer, the rental house is expected to provide equipment familiarization to customers upon delivery. This means being prepared to demonstrate the control functions and safety devices for each specific piece of equipment. If a customer requests training, the rental house must either offer it directly or refer the customer to a reasonable alternative source for proper instruction.
User Responsibilities
In addition to dealer obligations, rental houses also assume the responsibilities of a “user.” A user is defined as any entity who authorizes and directs operators in the use of MEWPs. Whenever a rental house directs its own personnel to operate a MEWP for loading, unloading, inspecting, sales demonstrations, or any form of use, it must fully comply with all user responsibilities outlined in the updated A92 safe use and training standards.
Tony Groat, IPAF North America manager, put it plainly: “Rental companies need to read and fully understand the updated standards in order to comply internally and additionally, to be able to fully assist their customers to meet their responsibilities. If they cannot get things straight in their own house, so to speak, they cannot possibly help customers to do so.”
He added, “The rental company is the leader of the band. If they are off key, the rest of the band will be off key too. If they are not doing things correctly, they will be showing everyone else the wrong way.”
Internal Operations and Employee Safety
Despite not being typical equipment “users” on construction sites, rental houses employ people who operate MEWPs regularly. Mechanics, sales personnel, and delivery drivers all may need to operate lifts within the facility or on job sites. These employees must be trained and supervised just like any other MEWP operator. Rental houses are obligated to maintain a MEWP safe-use plan and to evaluate operator proficiency on an ongoing basis.
Training, Familiarization, and Operator Proficiency Requirements
Training and familiarization form the backbone of ANSI A92 compliance. The updated standards expand on previous requirements with far more detail, ensuring that users are being as thorough as prior standards expected them to be.
Equipment Familiarization at Delivery
Rental houses are obligated to provide equipment familiarization to customers. Upon delivering a MEWP, the rental company must be prepared to show the customer the control functions and safety devices for that particular machine. This is not optional. Groat noted a classic challenge with existing standards: the assumption that familiarization occurs upon delivery on the job site. In reality, deliveries are often made after hours when no one is there to receive the equipment, or the person receiving the equipment is not the operator. Rental houses must plan for these scenarios and ensure familiarization still takes place.
Offering and Providing Training
If a customer requests training, the rental house is obligated to provide it or refer the customer to a qualified training provider. However, rental houses should be proactive rather than reactive. Many customers renting equipment do not know to ask for familiarization or training. It is the rental house’s responsibility to make customers aware of the need and to offer these services as a standard part of the rental process.
Operator Qualification and Proficiency Evaluation
Under the updated standards, once an operator completes training, the user can determine whether they are qualified to perform the work and then authorize them to operate the MEWP. The operator must periodically demonstrate continued proficiency. This evaluation is conducted by a designated qualified supervisor who is responsible for monitoring, supervising, evaluating, and documenting operators on a regular basis. Key aspects include:
- The supervisor should use reasonable judgment and determine proficiency based on actual performance
- Operators showing diminished performance must be retrained as needed
- All evaluations must be documented and records maintained
- The supervisor must complete specific training requirements defined in A92.24 Section 7.5, such as IPAF’s MEWPs for Managers course
Training Standards Comparison
| Training Component | Previous Standard | Updated A92 Requirement |
|---|---|---|
| Familiarization | Recommended at delivery | Mandatory at delivery with controls demonstration |
| Operator Training | General training suggested | Defined curriculum with documented proficiency |
| Supervisor Training | Not specifically defined | Formal training per A92.24 Section 7.5 |
| Proficiency Evaluation | One-time check | Ongoing periodic evaluation required |
| Documentation | Minimal record keeping | Written records for all training and evaluations |
Site Risk Assessment and Rescue Planning Obligations
One of the most significant changes in the updated ANSI A92 standards is the explicit requirement for site risk assessments and written rescue plans. While these concepts existed in prior standards, the new framework removes ambiguity and establishes clear, enforceable expectations.
Risk Assessment Requirements
The user must perform a risk assessment of the site before each use of a MEWP. This assessment must:
- Identify potential hazards in the work area, including overhead obstructions, soft ground conditions, and current wind and weather
- Evaluate the level of risk associated with each identified hazard
- Develop control measures to eliminate or mitigate those risks
- Communicate the findings and control measures to everyone affected
The user must also continuously revisit the site to determine if new hazards have emerged. Any changes must be documented and promptly communicated to everyone involved. As Groat explained, “A site risk assessment has always been needed, but typically has not been performed as intended. Starting with the updated standards, a risk assessment is specifically required, so users will clearly understand their responsibility.”
Written Rescue Plan
Rescue planning is a vital component of safe MEWP use and a necessary part of the site risk assessment. Under the new standards, users are required to develop a written rescue plan that addresses three primary scenarios:
- Machine breakdown where the operator is stranded at height
- Platform entanglement requiring rescue intervention
- Fall from platform requiring emergency response
The written rescue plan must be incorporated into the company’s training manual, and every employee must receive training that explains the procedures to follow in case of an emergency. Specific guidance on developing a compliant rescue plan can be found in A92.22 Section 6.1.2.6.
Equipment Selection as a Risk Control Measure
Once the site has been assessed, the next step is selecting and providing the right equipment for the job. There are many varieties of powered access equipment, each designed for specific applications. Rental houses must ensure customers are matched with equipment suitable for their specific job conditions. For optimum safety, the right lift for the task at hand should always be selected rather than simply making do with available inventory. This is both a safety imperative and a compliance requirement under the standards.
Design Standard Updates and What They Mean for Rental Fleets
While the safe use and training standards (A92.22 and A92.24) directly govern rental house operations, the design standard (A92.20) also has important implications for rental fleets and customer communication.
Platform Load Sensing Systems
One of the most notable new requirements in the design standard is platform load sensing on most MEWPs. This system identifies when the platform rated load is exceeded, sounds an alarm, and prevents normal machine movement. This helps prevent overloading and minimizes the risk of overturning and machine damage. Rental houses adding new equipment to their fleets must understand these systems and communicate their function to customers.
Grandfathering of Existing Equipment
MEWPs manufactured after the effective date must comply with A92.20 design requirements. However, machines manufactured to the existing standards do not require retrofitting. This grandfathering provision means rental fleets can continue operating existing equipment without modification, but any new machines added to inventory will feature the updated safety systems.
Customer Communication About New Features
Rental houses renting new equipment that meets the updated standards should note the load sensing capability to customers, especially those experienced with renting MEWPs. Explaining how this changes operation will reduce confusion, minimize needless calls for service, and ensure a more satisfactory rental experience. Practical steps for rental houses include:
- Updating rental agreements to acknowledge load sensing systems on new equipment
- Including a brief orientation on load sensing as part of the delivery familiarization
- Training counter staff and dispatchers to answer customer questions about the new systems
- Adding load sensing information to equipment manuals and quick-reference guides provided with rentals
Building a Compliance Framework for Your Rental House
Meeting ANSI A92 compliance is not a one-time task but an ongoing commitment. Rental houses that build a structured compliance framework will be better positioned to serve customers, protect employees, and avoid regulatory issues. The following checklist summarizes the key action items:
- Read and fully understand the updated A92.22 (safe use) and A92.24 (training) standards
- Designate a qualified supervisor responsible for operator training and proficiency evaluation
- Develop a written MEWP safe-use plan covering all company operations
- Create a written rescue plan and incorporate it into training materials
- Establish a risk assessment procedure that is performed before every MEWP use
- Train all employees who operate MEWPs, including mechanics and sales staff
- Implement a system for documenting all training, evaluations, risk assessments, and familiarization sessions
- Update rental delivery procedures to ensure equipment familiarization happens reliably
- Communicate new equipment features, such as load sensing, to customers proactively
- Periodically review and update compliance procedures as standards evolve
For rental houses looking to strengthen their market position, equipment rental profiles building a stronger rental business through industry visibility offers strategies for turning compliance into a competitive advantage. Understanding the broader rental market context, as outlined in the March 2021 rental industry report on equipment rental market trends, helps rental houses anticipate how regulatory changes affect demand. The ARA rental industry forecast for 2022 further highlights how equipment rental growth creates opportunities for compliant, well-prepared rental businesses.
ANSI itself is not a governing body and does not issue fines. It is an organization that coordinates the U.S. voluntary consensus standards system, providing a neutral forum for policy development. However, ANSI advises OSHA on its regulations, and OSHA regulations are enforced with fines for violations. Following ANSI standards is in everyone’s best interest because these standards foster worker safety and because failing to follow them could result in OSHA citations. Rental houses that invest in compliance today will be the industry leaders of tomorrow.