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.

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