Friday, December 21, 2012

Powered Industrial Truck (forklift) trainer qualifications

July 23, 2003

Dear Mr. Brant:

Thank you for your April 24 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Your letter has been referred to (DEP's) Office of General Industry Enforcement for an answer to your questions regarding powered industrial truck operator trainer qualifications. Your scenario and question has been restated below for clarity.

Background: 29 CFR 1910.178(l)(2)(iii) states: All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.

Scenario: Driver instructor examiners are training some powered industrial truck (PIT) operators. The driver instructor examiners have been certified to teach PIT operator training, however they do not operate PITs on a regular basis or as part of their job function and responsibility.

Question: What does OSHA mean by the word "experience" in 29 CFR 1910.178(l)(2)(iii)? Specifically, does it mean that the trainers must be certified to train drivers to operate PITs, or does it mean that the trainers must operate PITs on a regular basis as part of their job function and responsibility?

Reply: A trainer must have the "knowledge, training, and experience" to train others how to safely operate the powered industrial truck in the employer's workplace. In general, the trainer will only have sufficient "experience" if he has the practical skills and judgment to be able to himself operate the equipment safely under the conditions prevailing in the employer's workplace. For example, if the employer uses certain truck attachments and the trainer has never operated a truck with those attachments, the trainer would not have the experience necessary to train and evaluate others adequately on the safe use of those attachments. However, the standard does not require that the trainers operate a PIT regularly (i.e., outside of their operator training duties) as part of their job function or responsibility.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. OSHA interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at
http://www.osha.gov

Thursday, December 13, 2012

Is a Forklift considered a crane when it has the boom attachment?

June 21, 2012

The Honorable Jeff Miller
4300 Bayou Blvd, Suite 13
Pensacola, FL 32503

Dear Congressman Miller:

Thank you for your correspondence to the Department of Labor's Occupational Safety and Health Administration (OSHA) regarding the use of forklifts for construction activities.  I appreciate the opportunity to respond to you and your constituents.

In your inquiry, you forward a copy of an ASK OSHA e-correspondence submitted to OSHA on November 4, 2011, from your constituent Mr. Keith Raffield.  I appreciate your patience, as the process for achieving resolution to very complex compliance issues can be lengthy. Among several other major issues in the construction industry, OSHA has been in the process of responding to many interpretative inquiries such as this one regarding the scope and application of our final rule for Cranes and Derricks in Construction.

In his inquiry, Mr. Raffield asks OSHA the following question:

Question: Can I, as a forklift (not a crane operator) operator, use a designated forklift boom that has a hook on it as long as it meets the load requirements?

OSHA's response to Mr. Raffield's inquiry depends upon not only the original design of the forklift that is used, but also the design of the boom attachment and how the forklift and boom are operated together to move the load.  We recognize that our ASK OSHA webpage was not designed to provide for the submission of attachments with inquiries from the public, therefore the picture and description of the forklift in question that was provided with your inquiry was very helpful for making this determination.

Equipment that is designed to function as both a crane and a forklift would be considered multi-purpose equipment and covered by the crane standard when configured, and operated as, a crane.  However, Mr. Raffield submitted a picture of, and information about, a typical vertical mast forklift with a variable length boom attachment that uses slings or a rope to hoist and move a suspended load. This type of forklift described was designed by the manufacturer to lift palletized loads or those that can be safely handled and supported by the forks of the equipment.  The described configuration of a forklift, unlike a crane or derrick, can only provide powered horizontal and vertical movement of the suspended load by both driving the forklift horizontally in addition to moving its mast and forks.  Although the described boom attachment extends the reach of the forks, it was not designed to provide powered horizontal and vertical movement of the load.  This forklift configured with the described boom attachment is not covered by the cranes standard.

OSHA will continue to work with the industry and plans to issue responses to over 30 frequently asked questions to clarify requirements regarding the application of the Cranes and Derricks in Construction standard.  I hope you have found this letter helpful and informative.

Sincerely,

David Michaels, PhD, MPH

Monday, December 3, 2012

29 CFR 1910.178(e) High Lift Rider trucks clarification.

June 14, 1991
Mr. Mark Peters
Sales Manager
Clarklift of Kansas City, Inc.
2720 Nicholson
Kansas City, Missouri 64120


Dear Mr. Peters:

Thank you for your letter of May 28, requesting clarification of the Occupational Safety and Health Administration (OSHA) regulations 29 CFR 1910.178(e)(1), .178(e)(2), and .178(m)(9), dealing with requirements for backrest extensions and overhead guards for powered industrial trucks.

New High Lift Rider trucks acquired and used by an employer after February 15, 1972, must have an approved safety overhead guard to protect the forklift operator to comply with 29 CFR 1910.178(e)(1). The High Lift Rider truck is identified by the truck nameplate on which the capacity and load center of the truck load engaging means at maximum elevation must be indicated. Also, the rated capacities, alternate rated capacities, or alternate capacities may be included.

In order to comply with 29 CFR 1910.178(e)(2), new powered industrial trucks acquired and used by an employer after February 15, 1972, must have an approved vertical load backrest extension when the type of load being moved presents a hazard.

To comply with 29 CFR 1910.178.(m)(9), an overhead guard must be used on Low Lift powered trucks to offer protection to the truck operator from the impact of small packages, boxes, bagged material, etc., representative of the job application, but not to withstand the impact of a falling capacity load. The Low Lift truck is identifiable by the truck nameplate on which the rated capacity is indicated.

The information in your letter describing a forklift lifting a load approximately 48 inches high to a height of approximately 6 feet is not sufficient to evaluate your concern. The type of forklift, the type of load, and the position of the forklift operator, as well as the actual and potential heights of the load and of the lift, must be considered before a determination can be made as to which OSHA regulations apply.

We appreciate your interest in employee safety and health. If we can be further assistance, please do not hesitate to contact us.

Wednesday, November 28, 2012

Fall Protection Requirements for elevated platforms

Question 1: In regards to the use of fall arrest equipment and the use of body belts, do OSHA regulations require that a body belt be attached to a lanyard and used to protect personnel against falls from elevated "operator-up" high lift truck platforms, or do the standards state that a 5-point harness must be worn as a part of a fall arrest device?

Response: OSHA's powered industrial trucks (PITs) standard, contained in 29 CFR 1910.178, does not have provisions that require either the use of a body harness or safety belt to protect personnel against falls from elevated platforms. However, in the absence of a specific standard, OSHA can enforce Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act) -- which requires employers to protect employees from serious recognized hazards. Industry consensus standards, such as ASME B56.1-2000 Safety Standard for Low Lift and High Lift Trucks would be taken into consideration by OSHA when determining whether a hazard is "recognized" and that there is a feasible means of abating such a hazard. Section 4.17.2(c) of ASME 56.1-2000 requires that whenever an operator-up high lift truck is used to elevate personnel, restraining means such as railings, chains, cable, body belt(s) with lanyard(s), or deceleration devices, etc. are in place and properly used. Although the ASME standard calls for the use of body belts, OSHA strongly encourages employers to use body harnesses in place of body belts. You should also be aware that, as part of a rulemaking to revise Subpart D of 29 CFR 1910, OSHA has proposed the inclusion of a fall protection requirement that would apply to work platforms used in conjunction with powered industrial trucks. See the
No. 68 Federal Register 23528 (May 2, 2003). A copy of the relevant portion this Federal Register is enclosed.

Question 2: Can OSHA give me information on fines and the circumstances surrounding the fines, if a plant is found to be violating the fall arrest guidelines set forth by OSHA?

Response: During the course of an inspection, if an employer is found to expose his or her employees to fall hazards which could result in serious injuries, citations would be issued along with proposed penalties. The amount of proposed penalties varies, depending on the type of violation: Willful, Serious, Other-Than-Serious, Failure-to-Abate, and Repeat; and on the employer's size, good faith, previous history of violations, and the gravity of the violation. For example, OSHA may propose a penalty of up to $7,000 for each serious violation, whereas penalties for each willful violation may range from $5,000 to $70,000. Our penalty calculation procedures also give consideration for any employer with 250 or fewer employees. Normally, a reduction of 60 percent may be applied to penalties if the employer has 25 employees or fewer; 40 percent if the employer has 26-100 employees; and 20 percent if the employer has 101-250 employees. Although no reduction for size is applied if an employer has more than 250 employees, the employer may still be accorded up to a 10 percent reduction for a lack of previous violations, and a 25 percent reduction for "good faith," which mainly depends upon the effectiveness of the employer's safety and health program. When these three factors are combined, it is possible for the smallest employers to receive up to a 95 percent reduction in the initial monetary penalty. The enclosed OSHA 3000 publication, entitled "Employer Rights and Responsibilities Following an OSHA Inspection," which has additional details on the types of violations and associated penalties, may assist you in understanding our penalty structure associated with different types of violations for which citations are issued.

Monday, November 12, 2012

Preventing Injuries and Deaths of Workers Who Operate or Work Near Forklifts

Alerts briefly present new information about occupational illnesses, injuries, and deaths. Alerts urgently request assistance in preventing, solving, and controlling newly identified occupational hazards. Workers, employers, and safety and health professionals are asked to take immediate action to reduce risks and implement controls.

Notice to the Reader

The first edition of this Alert applied only to forklifts operated in a sitting position. However, this new edition includes a recommendation for employers and operators of stand-up forklifts with rear-entry access. In addition, the revised Alert contains several minor changes in wording to improve clarity.
WARNING!
Workers who operate or work near forklifts may be struck or crushed by the machine or the load being handled.
Workers: If you operate or work near forklifts, take these steps to protect yourself.
  • Do not operate a forklift unless you have been trained
  • Use seatbelts if they are available
  • Report to your supervisor any damage or problems that occur to a forklift during your shift
  • Do not jump from an overturning, sit-down type forklift. Stay with the truck, holding on firmly and leaning in the opposite direction of the overturn
  • Exit from a stand-up type forklift with rear-entry access by stepping backward if a lateral tip over occurs
  • Use extreme caution on grades or ramps
  • On grades, tilt the load back and raise it only as far as needed to clear the road surface
  • Do not raise or lower the forks while the forklift is moving
  • Do not handle loads that are heavier than the weight capacity of the forklift
  • Operate the forklift at a speed that will permit it to be stopped safely
  • Slow down and sound the horn at cross aisles and other locations where vision is obstructed
  • Look toward the travel path and keep a clear view of it
  • Do not allow passengers to ride on forklift trucks unless a seat is provided
  • When dismounting from a forklift, set the parking brake, lower the forks or lifting carriage, and neutralize the controls
  • Do not drive up to anyone standing in front of a bench or other fixed object
  • Do not use a forklift to elevate workers who are standing on the forks
  • Elevate a worker on a platform only when the vehicle is directly below the work area
  • Whenever a truck is used to elevate personnel, secure the elevating platform to the lifting carriage or forks of the forklift
  • Use a restraining means such as rails, chains, or a body belt with a lanyard or deceleration device for the worker(s) on the platform
  • Do not drive to another location with the work platform elevated
sit-down forklift
Typical sit-down type forklift
The National Institute for Occupational Safety and Health (NIOSH) requests assistance in preventing injuries and deaths of workers who operate or work near forklifts. Most fatalities occur when a worker is crushed by a forklift that has overturned or fallen from a loading dock.
NIOSH investigations of forklift-related deaths indicate that many workers and employers (1) may not be aware of the risks of operating or working near forklifts and (2) are not following the procedures set forth in the Occupational Safety and Health Administration (OSHA) standards, consensus standards, or equipment manufacturer's guidelines.
This Alert describes seven incidents resulting in the deaths of seven workers who were either operating or working near forklifts. In each incident, the deaths could have been prevented by using proper safety procedures and equipment and by following the provisions of the OSHA standards.
NIOSH requests that editors of trade journals, safety and health officials, industry associations, unions, and employers in all industries bring the recommendations in this Alert to the attention of all workers who are at risk.

Tuesday, November 6, 2012

Platform Attachment, Written Approval?

Background: The American Society of Mechanical Engineers (ASME) Safety Standard for Low Lift and High Lift Trucks B56.1-2000 contains specific requirements for elevating personnel on powered industrial trucks. For example, operator-up highlift trucks (order pickers, etc.) are addressed by paragraphs 4.17.1, 4.17.2, and 7.36. Trucks with work platforms that do not fit that category are covered by paragraphs 4.17.2, 4.17.3, and 7.36.3.

Question: Does 29 CFR 1910.178(a)(4) require an employer to obtain prior written approval from the original equipment manufacturer for the attachment of a work platform that meets the applicable requirements as outlined in paragraphs 4.17.2, 4.17.3, and 7.36.3 of ASME B56.1-2000?

Reply: Yes, written approval from the manufacturer of a powered industrial truck 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 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.

Thursday, November 1, 2012

Are there requirements for sound level of a horn on a forklift?

Question: When a forklift has a weak sounding horn, what determines whether it should be replaced or not?

Reply: OSHA's standard 29 CFR 1910.178(q)(7) requires that industrial trucks be inspected at least daily and not be placed into service if the examination shows any condition that may adversely affect the safety of the industrial truck. Additionally, §1910.178(p)(1) states, "If at any time a powered industrial truck is found to be in need of repair, defective, or in any way unsafe, the truck shall be taken out of service until it has been restored to safe operating condition." If the industrial truck is equipped with a horn as its warning device, then OSHA would consider the truck as being unsafe if the sound level of the horn has deteriorated to a level that can no longer be heard above the ambient noise in the workplace.

In addition, the employer must meet the requirements in §1910.178(q), Maintenance of industrial trucks. Specifically, §1910.178(q)(5) states, "All parts of any such industrial truck requiring replacement shall be replaced only by parts equivalent as to safety with those used in the original design."

Tuesday, October 23, 2012

OSHA Sample Daily Checklists

Sample Daily Checklists for Powered Industrial Trucks


The following checklists are intended to assist in providing training on OSHA's powered industrial truck operator standards. They are not a substitute for any of the provisions of the Occupational Safety and Health Act of 1970 or for any standards issued by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA). OSHA wishes to acknowledge that this checklist and related graphics was developed in cooperation with the Industrial Truck Association as part of the OSHA-ITA Alliance.

The OSHA standard for powered industrial truck training [29 CFR 1910.178(l)] requires that an employer provide training to truck operators on a variety of topics. Among these topics are vehicle inspection and maintenance that the operator will be required to perform. The following checklists are being provided as part of OSHA's ongoing effort to assist employers and employees in ensuring that a safe and healthful workplace is provided. The lists serve as a guide only and may not be totally inclusive. Each type of powered industrial truck is unique and checklists pertinent to each type of vehicle should be modified accordingly. It is recommended that the manufacturer's instructions on vehicle maintenance and owner's and operator's responsibilities also be consulted. The OSHA standards for powered industrial trucks must be reviewed to ensure compliance.

There are two general types of powered industrial trucks: electric (battery) powered and internal combustion engine (gas/LPG/diesel) powered. Each of these general types has a variety of different configurations and attachments. Your workplace may have a variety of trucks that are being operated. ALL OPERATORS MUST BE TRAINED TO OPERATE ALL TYPE OF INDUSTRIAL TRUCKS THEY WILL BE OPERATING. 

Daily, pre-shift inspection of powered industrial trucks is required by OSHA standards.

Depicted below are the major types of industrial trucks and some of the most common variations. The drawings of the trucks depicted below are intended to represent the typical configuration of trucks for each type. They do not include all available options, attachments or configurations.


Electric Motor Powered Industrial Trucks
Standup End Control Rider
Standup End Control Rider
Sitdown Rider
Sitdown Rider
Narrow Aisle Reach
Narrow Aisle Reach
Narrow Aisle High Lift Straddle
Narrow Aisle High Lift Straddle
Narrow Aisle Order Picker
Narrow Aisle Order Picker
Narrow Aisle Sideloader Platform
Narrow Aisle Sideloader Platform
Narrow Aisle Sideloader High Lift Pallet
Narrow Aisle Sideloader High Lift Pallet
Narrow Aisle Turret
Narrow Aisle Turret
Narrow Aisle Low Lift Platform
Narrow Aisle Low Lift Platform
Stacker Pallet
Stacker Pallet
Walkie Platform Low Lift
Walkie Platform Low Lift
Walkie Pallet Low Lift
Walkie Pallet Low Lift
Tractor Walkie/Rider
Tractor Walkie/Rider
Walkie Pallet High Lift
Walkie Pallet High Lift
 



Internal Combustion Engine Powered Industrial Trucks - Gas/LPG/Diesel
Counterbalanced Forklift Gas/LPG Cushion Tire
Counterbalanced Forklift Gas/LPG Cushion Tire
Counterbalanced Forklift Gas/LPG/Diesel Pneumatic Tire
Counterbalanced Forklift Gas/LPG/Diesel Pneumatic Tire
Tow Tractor Gas/LPG/Diesel
Tow Tractor Gas/LPG/Diesel
Rough Terrain Forklift Gas/LPG/Diesel Vertical Mast
Rough Terrain Forklift Gas/LPG/Diesel Vertical Mast


Daily checklists for each type of industrial truck are available from the truck manufacturer. You may choose to use a checklist for each type of industrial truck in your workplace or compile one that can be used for any type of truck.

Refer to the owner's manual, specifications and manufacturer's recommendations to modify the checklist for trucks being operated in your workplace. Below are sample checklists for internal combustion and electric trucks. These lists can be modified to suit your workplace needs.


Operator's Daily Checklist - Internal Combustion Engine Industrial Truck - Gas/LPG/Diesel Truck

Record of Fuel Added

Date   Operator   Fuel  
Truck#   Model#   Engine Oil  
Department   Serial#   Radiator Coolant  
Shift   Hour Meter   Hydraulic Oil  


SAFETY AND OPERATIONAL CHECKS (PRIOR TO EACH SHIFT)

Have a qualified mechanic correct all problems.

Engine Off Checks OK Maintenance
Leaks – Fuel, Hydraulic Oil, Engine Oil or Radiator Coolant    
Tires – Condition and Pressure    
Forks, Top Clip Retaining Pin and Heel – Check Condition    
Load Backrest – Securely Attached    
Hydraulic Hoses, Mast Chains, Cables and Stops – Check Visually    
Overhead Guard – Attached    
Finger Guards – Attached    
Propane Tank (LP Gas Truck) – Rust Corrosion, Damage    
Safety Warnings – Attached (Refer to Parts Manual for Location)    
Battery – Check Water/Electrolyte Level and Charge    
All Engine Belts – Check Visually    
Hydraulic Fluid Level – Check Level    
Engine Oil Level – Dipstick    
Transmission Fluid Level – Dipstick    
Engine Air Cleaner – Squeeze Rubber Dirt Trap or Check the Restriction Alarm (if equipped)    
Fuel Sedimentor (Diesel)    
Radiator Coolant – Check Level    
Operator's Manual – In Container    
Nameplate – Attached and Information Matches Model, Serial Number and Attachments    
Seat Belt – Functioning Smoothly    
Hood Latch – Adjusted and Securely Fastened    
Brake Fluid – Check Level    
Engine On Checks – Unusual Noises Must Be Investigated Immediately OK Maintenance
Accelerator or Direction Control Pedal – Functioning Smoothly    
Service Brake – Functioning Smoothly    
Parking Brake – Functioning Smoothly    
Steering Operation – Functioning Smoothly    
Drive Control – Forward/Reverse – Functioning Smoothly    
Tilt Control – Forward and Back – Functioning Smoothly    
Hoist and Lowering Control – Functioning Smoothly    
Attachment Control – Operation    
Horn and Lights – Functioning    
Cab (if equipped) – Heater, Defroster, Wipers – Functioning    
Gauges: Ammeter, Engine Oil Pressure, Hour Meter, Fuel Level, Temperature, Instrument Monitors – Functioning    


Operator's Daily Checklist - Electric Industrial Truck

Record of Fluid Added

Date   Operator   Battery Water  
Truck#   Model#   Hydraulic Oil  
Department   Serial#      
Shift   Drive Hour Meter Reading   Hoist Hour Meter Reading  


SAFETY AND OPERATIONAL CHECKS (PRIOR TO EACH SHIFT)

Have a qualified mechanic correct all problems.

Motor Off Checks OK Maintenance
Leaks – Hydraulic Oil, Battery    
Tires – Condition and Pressure    
Forks, Top Clip Retaining Pin and Heel -- Condition    
Load Backrest Extension – Attached    
Hydraulic Hoses, Mast Chains, Cables & Stops – Check Visually    
Finger Guards – Attached    
Overhead Guard – Attached    
Safety Warnings – Attached (Refer to Parts Manual for Location)    
Battery – Water/Electrolyte Level and Charge    
Hydraulic Fluid Level – Dipstick    
Transmission Fluid Level – Dipstick    
Operator's Manual in Container    
Capacity Plate Attached – Information Matches Model, Serial Number and Attachments    
Battery Restraint System – Adjust and Fasten    
Operator Protection
Sitdown Truck - Seat Belt – Functioning Smoothly
Man-up Truck – Fall protection/Restraining means - Functioning
   
Brake Fluid – Check level    
Motor On Checks (Unusual Noises Must Be Investigated Immediately) OK Maintenance
Accelerator Linkage – Functioning Smoothly    
Parking Brake – Functioning Smoothly    
Service Brake – Functioning Smoothly    
Steering Operation – Functioning Smoothly    
Drive Control – Forward/Reverse – Functioning Smoothly    
Tilt Control – Forward and Back – Functioning Smoothly    
Hoist and Lowering Control – Functioning Smoothly    
Attachment Control – Operation    
Horn – Functioning    
Lights & Alarms (where present) – Functioning    
Hour Meter – Functioning    
Battery Discharge Indicator – Functioning    
Instrument Monitors – Functioning    
ALL OPERATORS MUST BE TRAINED AND EVALUATED ON THE TYPES OF INDUSTRIAL TRUCKS AND ATTACHMENTS THEY WILL BE OPERATING.

Wednesday, October 17, 2012

Forklift equipped with a forklift boom considered a crane?

June 21, 2012

The Honorable Jeff Miller
Pensacola, FL 32503

Dear Congressman Miller:

Thank you for your correspondence to the Department of Labor's Occupational Safety and Health Administration (OSHA) regarding the use of forklifts for construction activities.  I appreciate the opportunity to respond to you and your constituents.

In your inquiry, you forward a copy of an ASK OSHA e-correspondence submitted to OSHA on November 4, 2011, from your constituent Mr. Keith Raffield.  I appreciate your patience, as the process for achieving resolution to very complex compliance issues can be lengthy. Among several other major issues in the construction industry, OSHA has been in the process of responding to many interpretative inquiries such as this one regarding the scope and application of our final rule for Cranes and Derricks in Construction.

In his inquiry, Mr. Raffield asks OSHA the following question:

Can I, as a forklift (not a crane operator) operator, use a designated forklift boom that has a hook on it as long as it meets the load requirements?

OSHA's response to Mr. Raffield's inquiry depends upon not only the original design of the forklift that is used, but also the design of the boom attachment and how the forklift and boom are operated together to move the load.  We recognize that our ASK OSHA webpage was not designed to provide for the submission of attachments with inquiries from the public, therefore the picture and description of the forklift in question that was provided with your inquiry was very helpful for making this determination.

Equipment that is designed to function as both a crane and a forklift would be considered multi-purpose equipment and covered by the crane standard when configured, and operated as, a crane.  However, Mr. Raffield submitted a picture of, and information about, a typical vertical mast forklift with a variable length boom attachment that uses slings or a rope to hoist and move a suspended load. This type of forklift described was designed by the manufacturer to lift palletized loads or those that can be safely handled and supported by the forks of the equipment.  The described configuration of a forklift, unlike a crane or derrick, can only provide powered horizontal and vertical movement of the suspended load by both driving the forklift horizontally in addition to moving its mast and forks.  Although the described boom attachment extends the reach of the forks, it was not designed to provide powered horizontal and vertical movement of the load.  This forklift configured with the described boom attachment is not covered by the cranes standard.

Wednesday, October 10, 2012

Skid-Steer Loader Operations Training

November 5, 2004

Mr. Mark Fair
Bobcat Enterprises

Re: Powered Industrial Truck Training applicable to construction: §§1910.178 and 1926.602(a) and (d).

Dear Mr. Fair:

This is in response to your fax of June 30, 2004, to the Occupational Safety and Health Administration (OSHA). We have paraphrased your questions as follows:

Question (1): Are the training requirements in §1910.178(l) applicable to skid-steer loaders used for earthmoving in construction? If not, what training requirements apply?

Answer: Title 29 CFR 1926.602(d) states:

Powered industrial truck operator training. NOTE: The requirements applicable to construction work under this paragraph are identical to those set forth at §1910.178(l) of this chapter.
Under §1926.602(d), employees engaged in construction who use equipment covered by 29 CFR Part 1926 Subpart O and the Powered Industrial Truck Standard (29 CFR 1910.178) must be trained in accordance with the requirements in §1910.178(l). However, §1910.178(a) states that the Powered Industrial Truck Standard does not apply "to vehicles intended primarily for earth moving...." Since skid-steer loaders are "intended primarily for earth moving," the training requirements in §1910.178(l) do not apply.1

However, 29 CFR 1926.21(b)(2) states:
The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his [or her] work environment to control or eliminate any hazards or other exposure to illness or injury.
Therefore, under §1926.21(b)(2), the employer is required to train the skid steer operators so that they can recognize and avoid unsafe conditions. As a practical matter, such training needs to be comprehensive enough to ensure that the operator is fully capable of safely handling the equipment in the type of conditions he/she will encounter at the site. The amount of training necessary to fulfill the requirement may be reduced based on the extent to which the operator has acquired the necessary knowledge and skill from prior experience (see the answer to Question 2, below).

Question (2): Section 1926.20(b)(4) provides that only those who are qualified through training or "experience" are allowed to operate equipment. In this context, what does "experienced" mean? If a worker has operated the equipment a number of times in the past, does that automatically mean they are "experienced" for purposes of this requirement?

Answer: No. Title 29 CFR 1926.20(b)(4) states:
The employer shall permit only those employees qualified by training or experience to operate equipment or machinery. [Emphasis added.]
The term "experience" in this provision is used in conjunction with the term "qualified." Where an operator, through prior experience, has acquired the knowledge and skill necessary to safely operate the equipment, the operator may be considered "qualified by...experience" for purposes of this provision. However, a history of having operated the equipment by itself does not necessarily mean that the operator knows how to safely and competently operate the equipment. The provision requires the operator to be "qualified." If the worker has operated the machinery in the past but has not acquired the knowledge and skills necessary to safely operate the equipment, the experience is not sufficient to make the employee "qualified."

Tuesday, July 17, 2012

Are jack stands sufficient support for semi-trailer when loading/unloading with a forklift?

April 14, 2008

Mr. Milton Pleasant
Alcoa Inc.
Reynolds Wrap Center
3041 Wilson Ave.
Louisville, KY 40211

Dear Mr. Pleasant:

Thank you for your letter of September 13, 2007, to the Occupational Safety and Health Administration's (OSHA's) regional office in Atlanta, Georgia. Your letter has been forwarded to OSHA's Directorate of Enforcement Programs (DEP). You had a question concerning OSHA's Powered industrial trucks standard, 29 CFR 1910.178, and the use of jack stands in the stabilization of semi-trailers. Your paraphrased question and our response follow.

Question: Are two jack stands, placed one on each side of the uncoupled end of a semi-trailer, sufficient to support the trailer and prevent it from upending during loading and unloading using powered industrial trucks? Is one jack stand placed in the middle of the uncoupled trailer sufficient?

Response: OSHA's Powered industrial trucks standard, at 29 CFR 1910.178(k)(3), states that "[f]ixed jacks may be necessary to support a semi-trailer and prevent upending during loading or unloading when the trailer is not coupled to a tractor." OSHA's standard does not specify a particular type of jack, nor the number and placement of such jacks. As noted in the March 19, 1991, letter to Mr. Thomas Wheeler (enclosed), the language in this paragraph is advisory rather than mandatory. However, when using portable jacks to support semi-trailers, OSHA strongly recommends following both the trailer and the jack manufacturer's instructions on the appropriate number and placement of these jacks. Additional guidance on the loading and unloading of trailers with powered industrial trucks may be found on OSHA's website at http://www.osha.gov/SLTC/poweredindustrialtrucks/loading_unloading.html.

You also enclosed a manufacturer's brochure depicting a particular type of portable jack. As you may know, OSHA does not approve, endorse, or promote any particular product, or protective measure.

For your information, the State of Kentucky administers its own occupational safety and health program under a plan approved and monitored by Federal OSHA. Therefore, employers in the State of Kentucky must comply with State occupational safety and health requirements. As a condition of plan approval, States are required to adopt and enforce occupational safety and health standards that are at least as effective as those promulgated by Federal OSHA. For the most part, Kentucky standards are identical to the Federal standards, although Kentucky does have some additional standards with different requirements. If you would like further information regarding Kentucky's occupational safety and health requirements, you may contact the Kentucky Department of Labor at the following address:

Steve Morrison, Executive Director
Office of Occupational Safety and Health
1047 U.S. Highway 127 S.
Suite 4
Frankfort, KY 40601
(502) 564-3070

Tuesday, May 8, 2012

Forklift Attachment Capacity

Can I put forklift lift capacity on attachment?

Our company has made some lift attachments, the forklift company will not make a new data plate since they did not make the attachment. Can we put the weight capacity on the attachment itself. we used the OSHA formula to come up with the Numbers.
 
Answer: NO!!!

Not unless you are a professional engineer. To satisfy the OSHA requirement you need to have the attachment evaluated by a professional engineer to determine how much it can hold. Then the forklift lifting capabilities should be evaluated based upon the center of gravity of the new attachment. You can then provide a data plate with the lifting limits of the attachment. However, the attachment should NEVER be marked with the weight limits of the forklift.

Keep in mind there are two limits here....#1 the structural capacity of the attachment and #2 the capacity of the forklift when using this specific attachment. To be OSHA compliant both need to be evaluated by a professional engineer.

Compliments of www.forklifttraining.ws

Tuesday, April 17, 2012

Safety Training Course Layout: Load Handling

Activity 6/7—LOAD HANDLING



  • Trainer B at Position 5 will provide verbal instruction and direction to
    continue driving portion as follows:

    • Assure horn is honked prior to proceeding

    • Driver will perform either Situation A or B

      • Situation A – Load-on-Top

        • Driver will pick up top load from Position 6 and

        • Place on ground at Position 7

        • Trainer will be checking for:

          • Approach;

          • Fork placement;

          • Fork depth;

          • Raising load;

          • Mast tilt;

          • Lowering load; and

          • Travel speed with load.





      • Situation B – Load-on-Ground

        • Driver will pick up ground load from Position 7 and

        • Place on top of load at Position 6

        • Trainer will be checking for:

          • Approach;

          • Fork placement;

          • Fork depth;

          • Raising load;

          • Mast tilt;

          • Lowering load; and

          • Travel speed with load.







    • Upon completion of load handling the driver will drive IN REVERSE to
      START/FINISH and park lift as close as possible to the cone without
      hitting it.





Activity 8


Trainer A at Position 8—START/FINISH will:



  • Provide feedback regarding:

    • Parking (also remember 25' and no line of sight):

      • Forks down;

      • Mast tilted;

      • Transmission to neutral;

      • Set emergency brake;

      • Engine/Power off;

      • Keys out of ignition;


      • Dismount (3 point); AND

      • Be sure it does not block a fire door, fire exit, fire equipment
        or access to a switch box, sprinkler valve, and/or first aid or
        emergency equipment.





  • Once everyone has completed the driver portion the following should be
    discussed: (this can take place in the group classroom setting or at the driver
    training site)

    • Review of Data Plate:

      Note that any attachments or mast change added after the purchase
      of the forklift must listed on the data plate. If your forklift data plate
      is missing, illegible or does not have the proper information, report it
      immediately.

      • Capacity rating

      • Load center - The forklift's load center and capacity are printed
        on the data plate. The overall capacity of a forklift is a function
        of load center and the weight being carried. The load center is
        the distance from the face of the mast to the center of your load.
        The standard industry pallet is 48" long. Therefore, most
        warehouse forklifts have a 24"load center. When the center of a
        capacity load exceeds a forklift's printed load center, the center of
        gravity moves within the stability triangle causing a tipping
        hazard.

      • Weight of PIT



    • Stability Triangle—The stability of a forklift is most commonly
      referred to as the "Stability Triangle." This is because a forklift is
      designed like a backwards tricycle. If you look under a four-wheel
      forklift, you will see a three-point suspension.

    • Center of Gravity - On the Stability Triangle drawing, the dot
      indicates where the center of gravity is located on a forklift that is not
      in operation. If the center of gravity were to moves outside of the
      triangle when carrying a load, then the forklift would tip over. The
      center of gravity shifts toward the base of the triangle when a load is
      added. It also shifts when traveling and stacking. If the center of
      gravity shifts to one side because of traveling on uneven ground or
      carrying an uneven load, the forklift could tip laterally. If the forklift
      makes too fast a turn, the center of gravity moves outside of the
      triangle, causing the forklift to tip over.

    • Shifting Load Center - For example, a 4,500-pound capacity forklift
      based on a 24" load center carrying a 4,500 pound, 48" long load is
      within the safe operation guidelines. However, if the same forklift is
      carrying a 5,000 pound, 60" load it has a 30" load center. This
      exceeds the 24" load center of the forklift. This will cause the forklift
      to tip forward.

    • Trucks, Trailers and Docks

      • Wheel chocking - Be sure that brakes are set and that chocks are
        placed against the truck, trailer or freight car wheels to prevent
        movements while you are loading or unloading.
        It is the responsibility of the forklift operator (NOT THE TRUCK
        DRIVER) to make sure that the trailers they drive on are chocked.

      • Dock Locks

      • Trailer floor and ramps - Before forklifts enter freight cars, trucks,
        and trailers, the flooring should be checked for breaks or
        weaknesses.




      All dock boards and bridge plates have rated capacities. Be sure to
      verify the weight of the forklift and the load does not exceed the
      capacity of the dock board or bridge plate. All dock boards and
      bridge plates should be properly secured before they are driven
      over. Dock boards or bridge plates should be driven over
      carefully and slowly.




      • Trailer capacity - Check the trailer capacity.

      • Trailer tandems - Sliding tandems on trailers should be slid to the
        rear to support the tail of trailers as much as possible.





Friday, February 10, 2012

Safety Training Course Layout: Reverse Slalom

Activity 2/3 – REVERSE SLALOM

  • Trainer B at Position 1/2 will provide verbal instruction and direction to continue driving portion as follows:

    • Assure horn is honked prior to proceeding.

    • Walk with driver to first cone assuring driver proceeds with the first cone on their left-hand side (as illustrated in BLUE).

    • Driver will slalom through cones to Trainer A and circle the last cone.

    • Trainer A will guide Driver around last cone to assure continuation. GCC/IBT PIT Driver's Safety Training 6

    • Trainer A will continue slalom through remaining cones and continue through course to Position 3 (as illustrated in BLUE) following visual and auditory commands from Trainer B.

    • Trainer B will confirm that Driver performs STOP-HONK-GO at DOORWAY.

    • Trainer B will walk with Driver to Position 3 and STOP Driver.

    • Trainer B will confirm at STOP that emergency brake is set. (Confirm at STOP position that emergency brake is set, forks are lowered and the vehicle is neutralized and shut down for the safety of the instructor.)

      (You may want to discuss shutting down if stopped for long periods.)

    • Trainer B will provide feedback if needed.

Activity 4/5 – FORWARD SLALOM

  • Trainer B at Position 3/4 will provide verbal instruction and
    direction to continue driving portion as follows:


    • Assure horn is honked prior to proceeding.

    • Walk with driver to first cone assuring driver proceeds with the first
      cone on their right-hand side (as illustrated in RED).

    • B will confirm that Driver performs STOP-HONK-GO at DOORWAY

    • Driver will continue slalom through remaining cones and continue
      through course to Position 5 (as illustrated in RED) following visual
      and auditory commands from Trainer B).

    • Trainer B will walk with Driver to Position 5 and STOP Driver.

    • Trainer B will confirm at STOP that emergency brake is set. (Confirm at
      STOP position that emergency brake is set, forks are lowered and the vehicle is
      neutralized and shut down for the safety of the instructor.)

      (You may want to
      discuss shutting down if stopped for long periods.)

    • Trainer B will provide feedback if needed.

    • Trainer B will provide instruction on handling a load:


      • Approaching load - Make sure the forklift is square to the bin or
        rack, and is completely stopped before you start to raise the load.

      • Fork placement in skid—The driver should check and know the size
        of each skid and their forks and insert the forks as far as possible
        without breaching the opposite side

      • Fork depth in skid—Be sure you have your forks under at least 2
        thirds (2/3) of your load for stability. While the full load is best it is
        not always possible. The driver should ultimately be concerned
        with the load balance.


      • Raising load— Slowly raise the load to a safe driving height that is
        as close to the ground as possible. Never let anyone walk under a
        raised load. Always lower the load when stopped.

      • Mast tilt pick-up and drop-off.

      • When the load has reached the correct height to clear any obstructions
        or other loads tilt the mast back for stability.

      • When the load has reached the correct height to clear any
        obstructions or other loads inch forward and tilt the mast forward
        to place it.

      • Lowering load—Lower the forks enough to release the pressure on
        the pallet and back the forklift until the forks are clear.

      • Skid size – Most use standard 48" skids. The driver should always
        check skid size.

      • Travel speed with load—Drive as slow as possible, 5 MPH or less
        is suggested.

National Safety Compliance also provides training materials such as DVDs, Booklets, PowerPoints, Sample Checklist(s), etc. to aide with safety training for OSHA compliance.