Sunday, March 6, 2011

Forklift Modifications / Elevated Platforms

Question: Does OSHA require an employer to obtain prior written approval from the forklift original equipment manufacturer for the attachment of a work platform or other modification to the forklift?

Reply: Yes, written approval from the manufacturer of a powered industrial truck(forklift) is required for modifications and/or additions if the modifications and/or additions affect the capacity and safe operation of the truck. However, please be aware that OSHA would consider the lack of manufacturer's approval to be a "de minimis"(minor, no penalty) violation if the employer has obtained written approval from a qualified Registered Professional Engineer after receiving no response or a negative response from the powered industrial truck manufacturer. If the manufacturer's response was negative, then the engineer, prior to granting approval for the modification or addition, would need to perform a safety analysis and address all safety and/or structural issues contained in the manufacturer's disapproval.

Even where the addition of a work platform to a powered industrial truck is permitted under §1910.178(a)(4) or the "de minimis" policy stated above, employers must also address the fall hazards that result from the use of elevated platforms. OSHA has proposed revisions to Subpart D of 29 CFR Part 1910 that include, in a new section §1910.31, requirements for mobile elevating work platforms, mobile ladder stands, and powered industrial truck platforms. (See 55 FR 13396, April 10, 1990, and 68 FR 23530, May 2, 2003.) Until a final rule is promulgated, an employer's failure to prevent or correct, to the extent feasible, fall hazards from elevated work platforms might be citable as a violation of Section 5(a)(1) of the OSHAct. OSHA's evaluation of the existence of a serious, recognized hazard and the availability of feasible means of abatement would include consideration of the relevant provisions of the ASME B56.1-2000 standard.

To obtain copies of the OSHA regulations, please visit this link:

OSHA Regulations and Standards


  1. " aware that OSHA would consider the lack of manufacturer's approval to be a "de minimis"(minor, no penalty)" True as this is, I think that with increased attention to safety lately, you'll find that many decision-makers would choose to meet the manufacturer's recommendations. Workplace safety is of utmost importance, so be sure to consult a material handling expert if you have concerns.

  2. It is true that approval from the manufacturer is necessary for the modification of the any heavy duty vehicle for the sake of safety point of view.