OSHA has extensive regulations concerning Forklift design and use, that every employer and employee needs to comply with. At Colorado Safety Supply, we offer top notch forklift training and urge you or your employee to schedule your training before they expire at the end of the third year of certification. We offer classes for up to five individuals multiple times a month as requested. Please feel free to check out our scheduling section here and schedule your forklift training today or call (303) 537-5832. Below you can read the official rules from OSHA regarding PIT and Forklifts, it can never hurt to catch up on the latest rules and regulations from OSHA.
Overview
This analysis covers the safety requirements for powered industrial trucks (PITs), including forklifts, in general industry workplaces, and mechanized equipment in construction. The general industry rules are covered in the first half of this analysis. For information about forklifts and mechanized equipment in construction, scroll down to the CONSTRUCTION FORKLIFT AND MECHANIZED EQUIPMENT OVERVIEW section.
Each year, more than 34,000 injuries related to powered industrial trucks (PITs), or forklifts, occur in U.S. workplaces. Many employees are injured when lift trucks are inadvertently driven off loading docks, lifts fall between docks and an unsecured trailer, they are struck by a lift truck, or when they fall while on elevated pallets and tines. Most incidents also involve property damage, including damage to overhead sprinklers, racking, pipes, walls, and machinery. According to Occupational Safety and Health Administration (OSHA), most employee injuries and property damage can be attributed to lack of safe operating procedures, lack of safety rule enforcement, and insufficient or inadequate training. OSHA rules are designed to prevent such injuries.
General Industry Requirements
OPERATOR AGE RESTRICTION
29 CFR 570.58 (Order 7)
It is a violation of federal law for anyone under 18 years of age to operate a forklift under any circumstances.
GENERAL REQUIREMENTS
29 CFR 1910.178(a)
The PIT rule contains safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines.
Exceptions to the PIT rule. This rule does not apply to compressed air- or nonflammable compressed gas-operated industrial trucks, farm vehicles, or vehicles intended primarily for earthmoving or over-the-road hauling.
Relationship of the PIT rule to other OSHA standards. Forklifts used in logging operations must be equipped with overhead guards meeting the requirements of the American Society of Mechanical Engineers (ASME) B56.6-1992 (with addenda), "Safety Standard for Rough Terrain Forklift Trucks," which is incorporated by reference in 29 CFR 1910.6 (29 CFR 1910.266(f)(4)).
At construction sites and in commercial manufacturing facilities where batteries (such as industrial truck batteries) are serviced and handled, properly plumbed eyewash and body-drenching equipment must be available immediately adjacent to the workstation(s) and within the work area regardless of the personal protective equipment required and used (29 CFR 1910.151).
Employees working on or around forklifts who are potentially exposed to hazards related to equipment component contact with overhead lines must be trained in the inherent hazards of electricity and means of avoiding exposure to such hazards. The standard for Electrical Safety-Related Work Practices can be applied with respect to electrical hazards related to any size, utilization, or configuration of overhead power lines (29 CFR 1910.331-.335).
Design and construction requirements. All new PITs must meet the design and construction requirements established in the American National Standard for Powered Industrial Trucks, Part II, American National Standards Institute (ANSI) B56.1-1969, which is incorporated by reference in 29 CFR 1910.6, except for vehicles intended primarily for earthmoving or over-the-road hauling.
Modifications and additions that affect capacity and safe operation need the manufacturer’s prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals must be changed accordingly.
Nameplates and markings must be maintained in a legible condition.
Truck designations. For the purpose of the standard, there are 11 designations of industrial trucks or tractors: D, DS, DY, E, ES, EE, EX, G, GS, LP, and LPS.
Hazardous locations. PITs may not be used in atmospheres containing hazardous concentration of acetylene, butadiene, ethylene oxide, hydrogen (or gases or vapors equivalent in hazard to hydrogen, such as manufactured gas), propylene oxide, acetaldehyde, cyclopropane, diethyl ether, ethylene, isoprene, or unsymmetrical dimethylhydrazine (UDMH).
Table N-1 under 29 CFR 1910.178(c)(2)(iv) summarizes the use of PITs in various locations.
Overhead guards. High lift rider trucks must be fitted with overhead guards unless operating conditions do not permit.
Storage and handling of liquid fuels. The storage and handling of liquid fuels such as gasoline and diesel fuel must be in accordance with National Fire Protection Association (NFPA) Flammable and Combustible Liquids Code (NFPA No. 30-1969).
Storage batteries. The following requirements apply to storage batteries:
- Battery-charging installations must be located in areas designated for that purpose.
- Facilities must be equipped for flushing and neutralizing spilled electrolyte, for fire protection, for protecting the charging apparatus from damage by trucks, and for adequate ventilation for dispersal of fumes from gassing batteries.
- A conveyor, overhead hoist, or equivalent material-handling equipment must be provided for handling batteries.
- Reinstalled batteries must be properly positioned and secured in the truck.
- A carboy tilter or siphon must be provided for handling electrolyte.
- When charging batteries, acid must be poured into water; water must not be poured into acid.
- Trucks must be properly positioned and brakes applied before attempting to change or charge batteries.
- Care must be taken to ensure that vent caps are functioning. The battery (or compartment) cover(s) must be open to dissipate heat.
- Smoking is prohibited in the charging area.
- Precautions must be taken to prevent open flames, sparks, or electric arcs in battery-charging areas.
- Tools and other metallic objects must be kept away from the top of uncovered batteries.
Other requirements:
- Where general lighting is less than 2 lumens per square foot, auxiliary directional lighting must be provided on the truck.
- Concentration levels of carbon monoxide (CO) gas created by PIT operations must not exceed the levels specified in 29 CFR 1910.1000.
Trucks and railroad cars:
- The brakes of highway trucks must be set and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with PITs.
- Wheel stops or other recognized positive protection must be provided to prevent railroad cars from moving during loading or unloading operations.
- Fixed jacks may be necessary to support a semitrailer and prevent upending during the loading or unloading when the trailer is not coupled to a tractor.
- Positive protection must be provided to prevent railroad cars from being moved while dockboards or bridge plates are in position.
SEAT BELTS
OSHA does not have a specific standard that requires the use or installation of seat belts. However, Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act) requires employers to protect employees from serious and recognized hazards. Recognition of the hazard of PIT tipover and the need for the use of an operator restraint system is evidenced by certain requirements for PITs at ASME B56.1-1993—Safety Standard for Low Lift and High Lift Trucks. National consensus standard ASME B56.1-1993 requires that PITs manufactured after 1992 must have a restraint device, system, or enclosure that is intended to assist the operator in reducing the risk of entrapment of the operator's head and/or torso between the truck and ground in the event of a tipover. Therefore, OSHA would enforce this standard under Section 5(a)(1) of the OSH Act.
When an employer has been notified by a PIT manufacturer or association of the hazard of lift truck overturn and made aware of an operator restraint system retrofit program, OSHA may then cite Section 5(a)(1) of the OSH Act if the employer has not taken advantage of the program. Other employers that have PITs that are not equipped with operator restraint systems should strongly consider contacting the appropriate PIT manufacturer for advice on obtaining and installing such devices for the prevention of an accident or injury from a lift truck overturn hazard.
TRUCK OPERATIONS
29 CFR 1910.178(m)
There are specific rules for truck operation, including:
- Trucks must not be driven up to anyone standing in front of a bench or other fixed object.
- No person is allowed to stand or pass under the elevated portion of any truck, whether loaded or empty.
- Unauthorized personnel are not permitted to ride on PITs. A safe place to ride must be provided where riding of trucks is authorized.
- Placing arms or legs between the uprights of the mast or outside the running lines of the truck is prohibited.
- When left unattended, forks must be fully lowered, controls placed in neutral, power shut off, and brakes set. Wheels must be blocked if the truck is parked on an incline.
- A safe distance must be maintained from the edge of ramps or platforms while on any elevated dock, platform, or freight car.
- There must be sufficient headroom under overhead installations, lights, pipes, sprinkler system, etc.
- An overhead guard should be used as protection against falling objects.
- All traffic regulations must be observed.
- All emergency vehicles must be yielded to.
- Railroad tracks must be crossed diagonally whenever possible.
- The driver must slow down and sound horn at cross-aisles where vision is obstructed.
- Grades must be ascended or descended slowly.
- When ascending or descending grades in excess of 10 percent, loaded trucks should be driven with the load upgrade.
- Stunt driving and horseplay are not permitted.
- The driver is required to slow down for wet and slippery floors.
- Make sure dockboards and bridge plates are properly secured before they are driven over.
- Elevators should be approached slowly and then entered squarely after the elevator car is properly leveled. Once on the elevator, the controls shall be neutralized, power shut off, and the brakes set.
- Motorized hand trucks must enter elevator or other confined areas with load-end forward.
- Only loads within the loaded capacity of the truck and stable loads should be handled.
- Defective or unsafe PITs must be taken out of service.
- Fuel tanks must not be filled while the engine is running.
VEHICLE INSPECTION/MAINTENANCE MAINTENANCE
Scheduled maintenance is required for the safe operation of the vehicle. The employer must:
- Never operate a vehicle that requires maintenance or is in any way unsafe (29 CFR 1910.178(p)(1)).
- Remove from service any powered industrial truck not in safe operating condition. All repairs must be made by authorized personnel. Do not permit workers to attempt to fix it themselves unless they are trained and authorized to do so (29 CFR 1910.178(q)(1)).
- Perform preventive maintenance according to manufacturer's scheduled recommendations.
- Keep industrial truck in clean condition, free of lint, excess oil, and grease (29 CFR 1910.178(q)(10)).
Only “authorized” persons may make repairs to and perform maintenance on PITs. A worker’s authorization may be only for a specific task, such as refueling or battery replacement. OSHA’s training requirements for workers who perform forklift maintenance are found in 29 CFR 1910.178(f), 29 CFR 1910.178(g), and 29 CFR 1910.178(q).
Fuel handling and storage (1910.178(f)). Workers must know how to properly handle and store fuels. Specifically:
- Liquid fuels (gasoline and diesel fuel) must be stored and handled in accordance with NFPA Flammable and Combustible Liquids Code (NFPA No. 30-1969).
- Liquefied petroleum gas (LPG) fuel must be stored and handled in accordance with NFPA Storage and Handling of Liquefied Petroleum Gases (NFPA No. 58-1969).
Changing and charging storage batteries (1910.178(g)).Forklift maintenance workers should know, at a minimum:
- To repair the fuel and ignition systems of industrial trucks only in locations designated for such repairs
- To disconnect the batteries of trucks before repairing electrical systems
- To only use replacement parts that are equivalent with respect to safety to the truck’s original parts
- Not to alter industrial trucks so that the relative positions of the various parts are different from what they were originally
- Not to add extra parts not provided by the manufacturer without the manufacturer’s approval
- Not to eliminate parts without manufacturer’s approval
PREOPERATION INSPECTION
29 CFR 1910.178(q)(7)
OSHA requires that all forklifts be examined at least daily before being placed in service. Forklifts used on a round-the-clock basis must be examined after each shift.
The operator should conduct a prestart visual check with the key off and then perform an operational check with the engine running. The forklift should not be placed in service if the examinations show that the vehicle may not be safe to operate.
Before starting a vehicle, the operator must conduct a preoperation (or prestart) inspection that checks a variety of items, including, but not limited to:
- Fluid levels—oil, water, and hydraulic fluid.
- Leaks, cracks or any other visible defect, including hydraulic hoses and mast chains. Note: Operators should not place their hands inside the mast. Use a stick or other device to check chain tension.
- Tire condition and pressure, including cuts and gouges.
- Condition of the forks, including the top clip retaining pin and heel.
- Load backrest extension.
- Finger guards.
Safety decals and nameplates. Ensure that all warning decals and plates are in place and legible. Check that information on the nameplate matches the model and serial numbers and attachments.
- Operator manual on truck and legible.
- Operator compartment. Check for grease and debris.
- All safety devices are working properly, including the seat belt.
In addition to this general inspection, additional items should be checked depending on the forklift type (electric or internal combustion, including liquid propane).
OPERATIONAL INSPECTION
After completing the preoperational inspection, operators should conduct an operational inspection with the engine running. This inspection includes:
- Accelerator linkage
- Inch control (if equipped)
- Brakes
- Steering
- Drive control: forward and reverse
- Tilt control: forward and back
- Hoist and lowering control
- Attachment control
- Horn
- Lights
- Backup alarm (if equipped)
- Hour meter
Note: Unusual noises or vibrations should be reported immediately.
REMOVAL FROM SERVICE
The OSHA PIT standard lists a number of conditions under which a forklift must be removed from service. If the operator notes these conditions while driving, the operator must stop, park the vehicle, and get assistance.
- Any powered industrial truck not in safe operating condition shall be removed from service. All repairs shall be made by authorized personnel (29 CFR 1910.178(q)(1)).
- Defects when found must be immediately reported and corrected (29 CFR 1910.178(q)(7)).
- Any vehicle that emits hazardous sparks or flames from the exhaust system shall immediately be removed from service and not returned to service until the cause for the emissions of such sparks and flames has been eliminated (29 CFR 1910.178(q)(8)).
- When the temperature of any part of any truck is found to be in excess of its normal operating temperature, thus creating a hazardous condition, the vehicle shall be removed from service and not returned to service until the cause for such overheating has been eliminated (29 CFR 1910.178(q)(9)).
- No truck shall be operated with a leak in the fuel system until the leak has been corrected (29 CFR 1910.178(p)(4)).
General Industry Training
OPERATOR TRAINING
29 CFR 1910.178(l)
Employees must successfully complete a training program before operating a forklift.
Trainer qualifications. All operator training and evaluation must be conducted by persons who have the knowledge, training, and experience to train forklift operators and evaluate their competence.
Training should consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, videotape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.
Training program content. Powered industrial truck operators must be trained in specific topics. Employee training must cover:
- Operating instructions, warnings, and precautions
- Differences between the truck and the automobile
- Truck controls and instrumentation
- Engine or motor operation
- Steering and maneuvering
- Visibility (including restrictions due to loading)
- Fork and attachment adaptation, operation, and use limitations
- Vehicle capacity
- Vehicle stability
- Vehicle inspection and maintenance
- Refueling and/or charging and recharging of batteries
- Operating limitations
- Any other operating instructions, warnings, or precautions listed in the operator's manual
- Surface conditions where the vehicle will be operated
- Composition of loads to be carried and load stability
- Load manipulation, stacking, and unstacking
- Pedestrian traffic in areas where the vehicle will be operated
- Narrow aisles and other restricted places where the vehicle will be operated
- Hazardous (classified) locations where the vehicle will be operated
- Ramps and other sloped surfaces that could affect the vehicle's stability
- Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of CO or diesel exhaust
- Unique or potentially hazardous environmental conditions in the workplace that could affect safe operation
Refresher training. Refresher training and an evaluation of the effectiveness of that training must be provided when the employee operates the vehicle in an unsafe manner, has been involved in an accident or near-miss incident, is assigned to drive a different kind of truck, or there are changes in workplace conditions that could affect safe operation of the truck.
Triennial operator evaluation. An evaluation of each industrial truck operator's performance must be conducted at least every 3 years.
Duplication of training. If an operator has been previously trained and has been evaluated and found competent to operate the truck safely, additional training is not required.
Certification. The employer must certify that each operator has been trained and evaluated. The written certification record must include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation. Employers that evaluate the operator’s performance more frequently than every 3 years may retain the most recent certification record; otherwise, certification records must be maintained for 3 years.
Construction Forklift and Mechanized Equipment Requirements
Mechanized equipment in construction includes forklifts, earth-moving equipment, and other mechanized machines used to move all types of materials at the construction site. OSHA has developed rules for the safe design and use of mechanized equipment used for construction activities, including:
- Earthmoving equipment
- Excavation equipment
- Tractors
- Forklifts and other powered industrial trucks
Rollover protective structures (ROPS). There are additional requirements for earthmoving equipment related to ROPSs (including protective frames) and overhead protection.
EARTHMOVING EQUIPMENT
29 CFR 1926.602(a)
Applicability. The earthmoving equipment rule applies to scrapers, loaders, crawler or wheel tractors, bulldozers, off-highway trucks, graders, agricultural and industrial tractors, and similar equipment.
Note on mandatory consensus standards incorporated from the Society of Automotive Engineers (SAE), Power Crane and Shovel Association, and American National Standards Institute (ANSI): These organizations have updated the consensus standards cited in the regulation. OSHA allows employers to follow the updated consensus standards without penalty when they provide equal or greater employee protection.
Seat belts. Seat belts must be provided on all equipment and meet the requirements of the following industry consensus standards adopted by OSHA rules
- SAE J386–1969, Seat Belts for Construction Equipment
- SAE J333a–1970, Operator Protection for Agricultural and Light Industrial Tractors (agricultural and light industrial tractors)
Seat belts are neither required for equipment designed only for stand-up operation, nor for equipment that does not have rollover protective structure (ROPS) or adequate canopy protection.
Access roadways and grades. Construction equipment or vehicles must not be moved on any access roadway or grade unless it is constructed and maintained to safely accommodate the movement of the equipment and vehicles. Every emergency access ramp and berm used by an employer must be constructed to restrain and control runaway vehicles.
Brakes. All earthmoving equipment must have a service braking system capable of stopping and holding the equipment fully loaded, as specified in SAE J237 Loader Dozer–1971, J236 Graders–1971, and J319b Scrapers–1971. Brake systems for self-propelled rubber-tired off-highway equipment must meet the applicable minimum performance criteria in the following SAE consensus standards:
- SAE J319b–1971 Self-Propelled Scrapers
- SAE J236–1971 Self-Propelled Graders
- SAE J386–1969, Seat Belts for Construction Equipment
- SAE J166–1971 Trucks and Wagons
- SAE J237–1971 Front End Loaders and Dozers
Fenders. Pneumatic-tired earthmoving haulage equipment (trucks, scrapers, tractors, and trailing units) whose maximum speed exceeds 15 miles per hour must be equipped with fenders on all wheels to meet the requirements of SAE J321a–1970, Fenders for Pneumatic-Tired Earthmoving Haulage Equipment. An employer may seek to show that the uncovered wheels present no hazard to personnel from flying materials.
Audible alarms. All bidirectional machines, such as rollers, compacters, front-end loaders, bulldozers, and similar equipment, must be equipped with a horn distinguishable from the surrounding noise level which must be operated as needed when the machine is moving in either direction. The horn must be maintained in an operative condition.
The employer must prohibit earthmoving or compacting equipment that has an obstructed view to the rear to be used in reverse gear unless the equipment has a working reverse signal alarm distinguishable from the surrounding noise level, or an employee signals that it is safe to do so.
Guarding scissor points. Scissor points on all front-end loaders must be guarded if the points constitute a hazard to the operator during normal operation.
EXCAVATING EQUIPMENT
29 CFR 1926.602(b)
Tractors must have seat belts for the operators when seated in the normal seating arrangement for tractor operation, even though backhoes, breakers, or other similar attachments are used on these machines for excavating or other work.
Equipment specifications. The nomenclatures and descriptions for measurement of dimensions of machinery and attachments must be as described in the SAE 1970 Handbook, or updated version.
Equipment must comply with the safety requirements, ratios, or limitations applicable to machines or attachment usage covered in Power Crane and Shovel Associations Standards No. 1 and No. 2 of 1968 and No. 3 of 1969, or updated versions, and must apply to cranes, machines, and attachments.
FORKLIFTS AND OTHER POWERED INDUSTRIAL TRUCKS
29 CFR 1926.602(c)
ANSI standards. All industrial trucks in use must meet the requirements of ANSI B56.1-1969, Safety Standards for Powered Industrial Trucks. All high lift rider industrial trucks must be equipped with overhead guards meeting the configuration and structural requirements of ANSI B56.1-1969
Capacity. OSHA construction standards require that lift trucks have the rated capacity clearly posted on the vehicle and visible to the operator. When auxiliary removable counterweights are provided by the manufacturer, corresponding alternate rated capacities must also be clearly shown on the vehicle. Ratings must not be exceeded
If a load is lifted by two or more trucks working in unison, the proportion of the total load carried by any one truck should not exceed its capacity.
Modifications. No modifications or additions which affect the capacity or safe operation of the equipment may be made without the manufacturer’s written approval. If such modifications are made, the capacity, operation, and maintenance instructions plates, tags, or decals must be changed accordingly.
Safe operating requirements. Following are additional requirements for the safe operation of forklifts:
- Steering or spinner knobs must not be attached to the steering wheel unless the steering mechanism is of a type that prevents road reactions from causing the steering handwheel to spin. The steering knob must be mounted within the periphery of the wheel.
- Unauthorized personnel are not permitted to ride on forklifts. A safe place to ride must be provided where riding of trucks is authorized.
- Trucks with lifting carriages or forks for lifting personnel must use a safety platform firmly secured to the lifting carriage or forks. Means must be provided so personnel on the platform can shut off power to the truck and protection from falling objects must be provided.
- Equipment left unattended at night, adjacent to a highway in normal use, or adjacent to construction areas where work is in progress must have appropriate lights or reflectors.
- The parking brake must be set when forklifts are parked
- Wheels must be chocked when parked on an incline.
Lifting and hauling. Industrial trucks must comply with this rule and the following additional requirements:
Lift trucks, stackers, and similar equipment must have the rated capacity clearly posted on the vehicle so as to be clearly visible to the operator. When the manufacturer provides auxiliary removable counterweights, corresponding alternate rated capacities must also be clearly shown on the vehicle. These ratings must not be exceeded.
No modifications or additions that affect the capacity or safe operation of the equipment must be made without the manufacturer’s written approval. If such modifications or changes are made, the capacity, operation, and maintenance instruction plates, tags, or decals must be changed accordingly. In no case must the original safety factor of the equipment be reduced.
If a load is lifted by two or more trucks working in unison, the proportion of the total load carried by any one truck must not exceed its capacity..
Steering or spinner knobs must not be attached to the steering wheel unless the steering mechanism is of a type that prevents road reactions from causing the steering handwheel to spin. The steering knob must be mounted within the periphery of the wheel.
All high-lift rider industrial trucks must be equipped with overhead guards that meet the configuration and structural requirements as defined in ANSI B56.1–1969, Safety Standards for Powered Industrial Trucks.
All industrial trucks in use must meet the applicable requirements of design, construction, stability, inspection, testing, maintenance, and operation as defined in ANSI B56.1–1969, Safety Standards for Powered Industrial Trucks.
Unauthorized personnel must not be permitted to ride on powered industrial trucks. A safe place to ride must be provided where riding of trucks is authorized.
Whenever a truck is equipped with vertical only or vertical and horizontal controls that can elevate with the lifting carriage or forks for lifting personnel, the following additional precautions must be taken for the protection of personnel being elevated:
Provide a safety platform firmly secured to the lifting carriage and/or forks.
Provide personnel on the platform a means to shut off power to the truck.
Provide appropriate protection from falling objects.
ROPS
ROPSs are used to protect construction employees operating all rubber-tired, self-propelled scrapers, rubber-tired front-end loaders, rubber-tired dozers, wheel-type agricultural and industrial tractors, crawler tractors, crawler-type loaders, and motor graders in the event the equipment becomes unstable and tips over. ROPSs must meet specific design and testing requirements called for in OSHA regulations.
Following are the citations for the ROPS rules:
- 29 CFR 1926.1000—ROPS for material-handling equipment
- 29 CFR 1926.1001—Minimum performance criteria for ROPS
- 29 CFR 1926.1002—ROPS for wheel-type agricultural and industrial tractors used in construction
- 29 CFR 1926.1003—Overhead protection for operators of agricultural and industrial tractors
- Construction Training
- 29 CFR 1926.602(c)
The requirements for PIT operator training applicable to construction are identical to the general industry operator requirements at 29 CFR 1910.178(l). For more information, see the GENERAL INDUSTRY TRAINING section