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

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.


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.