ANSI MEWP training requirements changed more in 2018 than in the thirty years before it, and most training programs have not caught up. The old aerial work platform standards asked whether an operator had been trained. The A92 series that replaced them, in force since June 1, 2020, asks a longer set of questions: was the operator trained for the classification of machine they are on, were they familiarized on the specific model, have the occupants been trained, has the supervisor been trained, did the user do a risk assessment and write a rescue plan, and can every one of those be shown on paper. A three-year-old wallet card answers none of them. This guide lays out what ANSI/SAIA A92.24 actually requires, who it applies to, how it fits with OSHA’s rules, and what a program built to the standard looks like on a jobsite and in a file cabinet.
If your question is only about renewal intervals, the companion post on how long aerial lift certification is good for covers that in detail. This one is about content: what the training has to include and who has to receive it.
Three standards, one system: A92.20, A92.22 and A92.24
The 2018 revision replaced the machine-type standards (A92.3 for manually propelled platforms, A92.5 for boom-supported platforms, A92.6 for self-propelled platforms, and so on) with three documents organized by responsibility instead of by machine.
- ANSI/SAIA A92.20 is the design standard. It is written for manufacturers and is the reason newer machines have load-sensing systems, tilt cutouts, and the platform capacity and wind-rating decals that operators are now trained to read.
- ANSI/SAIA A92.22 is the safe use standard. It is written for the “user,” the entity that has care, custody and control of the machine, which on most jobs means the employer. It requires a safe use program: a workplace risk assessment before the work, selection of the right MEWP for it, a rescue plan, and the assignment of trained people to run it.
- ANSI/SAIA A92.24 is the training standard. It defines what operator, occupant and supervisor training must cover, requires familiarization on each model, and sets the record-keeping and retraining expectations that the rest of this post is about.
The three are meant to be read together. A92.24 tells you what to teach; A92.22 tells you what the people you taught are supposed to do with it; A92.20 explains why the machine behaves the way the training says it will. The standards are published through the Scaffold & Access Industry Association and sold through ANSI; the summary here is a guide to the structure, and the text itself governs where they differ.
Who has to be trained
The single biggest change in the 2018 standards is that “operator training” stopped being the whole program. A92.24 names three groups, and a program that trains only the first is not compliant with the standard even if every operator holds a current card.
Operators
Anyone who runs a MEWP from its controls. Operator training is the most detailed requirement in the standard and the one most programs already deliver in some form. It has to be specific to the classification of machine, and it has to include a hands-on evaluation on a MEWP of the type the operator will use. A classroom session with a quiz is not operator training under A92.24.
Occupants
Anyone on the platform who is not the operator. Occupant training is shorter but not optional: occupants have to understand the fall protection requirements, the hazards of the work and the platform, how to keep themselves and their tools inside the guardrails, and enough about the controls to lower the platform if the operator is incapacitated. The last item surprises employers, and it is the reason a rescue plan under A92.22 usually starts with the occupant rather than a ground crew.
Supervisors
Anyone who directs or monitors MEWP work. A92.24 requires that supervisors be trained to select the right machine for the task, to recognize the hazards and know the rules that apply, to confirm that the manuals are on the machine, and to verify that operators and occupants have been trained and familiarized. In practice this is the foreman who tells a crew to “grab the scissor lift and get that conduit run.” If that foreman has never been trained to know when the scissor lift is the wrong machine, the standard says the program has a gap, and so will an incident investigation.
Maintenance and inspection personnel
The standard also expects the people who inspect, test and maintain MEWPs to be trained for that work in accordance with the manufacturer’s requirements and the standard. Rental yards and in-house shops carry that duty; contractors who rent and only operate do not, but they do have to make sure the pre-start inspection is part of operator training, which is where the two responsibilities meet.
What operator training has to cover
A92.24 lists the subjects operator training must include. Paraphrased into the order a good class actually runs them:
- The manuals. Where the operator’s manual and the safety manual are stored on the machine, and that they are the authority on that machine’s use.
- Pre-start inspection. The walk-around and function test before each shift, what a defect looks like, and the rule that a MEWP with a defect that affects safety is taken out of service, not driven carefully.
- Responsibilities for problems and malfunctions. Who the operator reports to, and that the operator has the authority to stop.
- Factors affecting stability. Platform load and its distribution, ground and floor conditions, slope, wind, side forces from tools and materials, and the way outriggers, tires and the machine’s own geometry keep it upright or do not. This is where the Group A versus Group B distinction is taught, because the two groups tip differently.
- Placards, decals and warnings. Reading the capacity plate, the wind rating, the indoor-only marking, and the manufacturer’s warnings, and understanding that they are operating limits rather than suggestions.
- Workplace inspection and risk assessment. Identifying overhead hazards, drop-offs, holes, debris, soft ground, energized lines, traffic, and other people, and matching the machine and the plan to what was found.
- Safety rules and regulations. The applicable OSHA standards, the site rules, and the A92.22 safe use requirements including the rescue plan.
- Authorization. That operating a MEWP requires the employer’s authorization, and that authorization follows training and familiarization rather than preceding them.
- Operator warnings and instructions. Fall protection use by classification, entrapment hazards, the prohibition on climbing the guardrails or using the platform as a crane, and the specific instructions in the manufacturer’s manual.
- Actual operation. Hands-on time on a MEWP of the classification being trained for, with the operator demonstrating each function under the trainer’s observation and being evaluated on it.
The classification matters because training is issued by classification, not by brand. Under the A92 system a machine is described by group and type:
| Classification | Definition | Typical machines |
|---|---|---|
| Group A | The platform’s vertical projection stays inside the tipping lines at all times | Scissor lifts, most vertical mast lifts |
| Group B | The platform can extend beyond the tipping lines | Articulating and telescopic boom lifts, some mast lifts with jibs |
| Type 1 | Travel is allowed only with the platform stowed | Push-around and some trailer-mounted units |
| Type 2 | Travel with the platform elevated is controlled from the chassis | Some truck-mounted and specialty units |
| Type 3 | Travel with the platform elevated is controlled from the platform | Most self-propelled scissor and boom lifts |
An operator trained on a Group A, Type 3 scissor lift is trained for scissor lifts. Putting that operator on a Group B, Type 3 boom lift requires training for Group B, not just a walk-around, because the stability lesson, the fall protection lesson and the entrapment lesson are all different. The searches for “3A MEWP” and “3B MEWP” that bring people to our aerial lift training page are usually this question in shorthand: 3A is a Group A, Type 3 machine and 3B is a Group B, Type 3 machine, and the training record has to say which.
Familiarization: the requirement most programs skip
Training is about the classification; familiarization is about the machine. A92.24 requires that before an operator uses a particular make and model for the first time, they are familiarized with it: where the manuals are kept, the purpose and function of every control, the safety devices and their behavior, and the operating characteristics specific to that model. Familiarization is delivered by someone who knows the machine, which on a rental delivery is typically the rental company’s driver and on a company-owned fleet is a designated operator or supervisor. It takes minutes, and its absence shows up in incident files more often than any other single gap, because “trained on scissor lifts” does not mean “knows that this scissor lift has a pothole protection system that locks the drive when it deploys.”
The program fix is a familiarization log: model, date, operator, and who delivered it. One line per machine. An employer with a mixed rental fleet on a large site can keep it at the gate with the daily pre-start forms. Our aerial lift train the trainer course prepares your own people to deliver and log it.
Evaluation and retraining under A92.24
The standard puts the duty to evaluate operators on the user. It expects the user to observe operators, to evaluate their knowledge and performance, and to retrain when the evaluation, an incident, a change in the type of MEWP, or a change in conditions shows that retraining is needed. It does not put a number of years on the interval, and the three-year figure most programs use comes from OSHA’s powered industrial truck rule rather than from the A92 series. A program that adopts a fixed interval satisfies the standard as long as the triggers override it; a program that has no interval and no documented evaluations does not, because it cannot show the evaluation ever happened.
The hands-on evaluation at initial training and the periodic evaluation afterward are the two records that an auditor with the standard open will ask for by name. Our program delivers both on the customer’s own machines and leaves the completed evaluation forms with the training record; the equipment operator training page describes how that is scheduled.
ANSI MEWP training requirements vs OSHA: which one governs?
Both, in different ways. OSHA’s construction standard, 29 CFR 1926.454, requires training by a person qualified in the subject matter for anyone working on a scaffold, and OSHA treats scissor lifts as scaffolds (interpretation of August 1, 2000). Aerial lifts are not scaffolds: 1926.450(a) sets their criteria out exclusively in 1926.453, which says only authorized persons shall operate an aerial lift. The general industry standard, 29 CFR 1910.67, requires in (c)(2)(ii) that only trained persons operate an aerial lift. 1926.453 and 1910.67 both incorporate the 1969 edition of ANSI A92.2 by reference, which is the only ANSI text that is literally part of the regulation. The 2018 standards are voluntary consensus standards; OSHA has not adopted them into the rule.
That does not make them optional in practice. OSHA cites consensus standards under the general duty clause as evidence of recognized hazards and feasible abatement, and the A92 series is the current industry statement of how MEWP work is supposed to be done. Owners, general contractors and federal specifications write the current ANSI edition into their requirements directly. And the manufacturer’s manual on every machine built to A92.20 tells the operator to comply with A92.22 and A92.24. The realistic position for an employer is that OSHA sets the floor, the A92 series sets the standard of care, and the site rules set the interval and the paperwork.
| Requirement | OSHA 1926.453 / 1926.454 / 1910.67 | ANSI/SAIA A92.24-2018 |
|---|---|---|
| Operator training | Required: trained (1910.67) or authorized (1926.453) operators; scaffold and scissor lift users trained by a qualified person (1926.454) | Required, by classification, with listed content and hands-on evaluation |
| Familiarization on each model | Not addressed by name | Required before first use of each make and model |
| Occupant training | Not addressed by name | Required, including emergency lowering |
| Supervisor training | Not addressed by name | Required for anyone directing or monitoring MEWP work |
| Risk assessment and rescue plan | General duty; site-specific fall protection rules | Required of the user under A92.22; taught under A92.24 |
| Retraining | On changed conditions, equipment or observed inadequacy (1926.454(c)) | On evaluation, incident, new type or changed conditions |
| Renewal interval | None stated | None stated; user sets it |
| Records | Employer must be able to demonstrate training | Training records kept, with trainee, trainer, date and content |
Fall protection is part of the training, not a separate class
A92.24 makes fall protection an operator and occupant training subject, and the rule it teaches depends on the machine. On boom-supported platforms, everyone on the platform wears a full body harness with a lanyard attached to the manufacturer’s anchorage, because a Group B machine can throw an occupant over the rail when the boom flexes or the chassis hits a hole. On scissor lifts and other Group A machines the guardrail is the primary fall protection, and the manufacturer’s manual and the site rules decide whether a harness is also required; many owners require one on every MEWP regardless, and the training should say so. Whichever rule applies, the harness has to fit, the lanyard has to be short enough to keep the occupant inside the rail, and the equipment has to pass the inspection covered in the fall protection equipment inspection post. Employers whose crews also work at height off the platform usually pair MEWP training with fall protection training so the harness lesson is taught once, correctly.
Records that satisfy an auditor
The standard requires the entity that delivers training to keep records, and the user to be able to show who has been trained, familiarized and evaluated. The file that answers every question we have seen asked, by OSHA, by owners and by insurers, has five parts:
- Operator training record: trainee, trainer and training entity, date, the classifications covered (Group A or B, Type 1, 2 or 3), the subjects covered, and the result of the hands-on evaluation.
- Familiarization log: make and model, date, operator, who delivered it.
- Occupant training roster: names, date, content, trainer.
- Supervisor training record: the same fields as the operator record without the hands-on evaluation.
- Evaluation and retraining log: date, evaluator, machine, result; for retraining, the trigger and what was delivered.
Federal projects add a layer. Work under the U.S. Army Corps of Engineers safety manual, EM 385-1-1, requires MEWP operators to be trained in accordance with the ANSI A92 series and expects the documentation on site; the edition your contract cites controls the details, and the same manual’s fall protection sections, covered in the EM 385 fall protection requirements post, apply to the platform work. The file above satisfies the government’s representative as long as it is complete and on site, and it satisfies the prequalification questionnaire that increasingly asks for it before award.
Common questions
Are the ANSI MEWP training requirements legally required?
The A92 standards are voluntary consensus standards, not OSHA regulations. OSHA requires aerial lift operators to be trained (1910.67(c)(2)(ii)) or authorized (1926.453(b)(2)(ii)), applies its construction scaffold training rule, 1926.454, to scissor lifts, and can cite the general duty clause using the A92 series as evidence of recognized practice. Owners, contractors and federal specifications frequently make the current ANSI edition a contract requirement. Treat A92.24 as the standard of care.
What is the difference between MEWP training and familiarization?
Training covers a classification of machine: the hazards, rules, stability factors, inspection and hands-on operation for Group A or Group B, Type 1, 2 or 3. Familiarization covers one specific make and model: its manuals, controls, safety devices and operating characteristics. Both are required before an operator runs a machine, and both are recorded separately.
Do occupants who never touch the controls need training?
Yes. A92.24 requires occupant training covering fall protection, platform hazards, keeping tools and people inside the guardrails, and enough knowledge of the controls to lower the platform in an emergency. It is short, and it is the part of the rescue plan that works when nobody is on the ground.
Does supervisor training mean the supervisor has to be an operator?
No. Supervisor training is about selection, hazards, rules, manuals and verifying that the crew is trained and familiarized. Many supervisors are also trained operators, which helps, but the two records are distinct and a supervisor who never operates still needs the supervisor training.
What does 3A or 3B mean on a MEWP card?
The type followed by the group. 3A is a Type 3 (travel elevated, controlled from the platform), Group A (platform stays inside the tipping lines) machine, which describes most self-propelled scissor lifts. 3B is Type 3, Group B, which describes most self-propelled boom lifts. A card marked 3A does not cover boom lifts.
Can online training satisfy A92.24?
Online delivery can cover the knowledge portion. It cannot deliver the hands-on evaluation on a machine of the right classification, or the familiarization on a specific model, and a program that stops at the online certificate has not met the standard. Blended programs that pair an online module with an in-person evaluation are common and compliant when the evaluation is documented.
Build the program the standard describes
The standard is not asking for more classes; it is asking for a system that names who runs the machine, who rides it, who assigns the work, and how each of them was prepared. Tell us which classifications your crews operate, how many operators, occupants and supervisors you have, and which owners or contracts you work under, and we will scope aerial lift training to A92.24 on your machines, deliver the evaluations and familiarization with it, and hand you the five-part file. Tell us about your fleet and your sites and we will come back with a plan you can show an auditor.
About the Author
Patrick Salazar — founder of 3P Safety and an OSHA 500 authorized construction outreach trainer, working NCCCO-certified mobile crane operator (LBC, TLL, TSS), tower crane operator, certified crane inspector, and lift director. In the field since 2005, delivering instructor-led safety training at jobsites and facilities nationwide. General Industry outreach courses are taught by our team's OSHA 501 authorized trainer.

