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Forklift Safety Frequently Asked Questions

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General Compliance     |    Definitions    |    Inspections    |    Seat Belts

General Compliance

What is a recommended speed for forklifts operating within a manufacturing facility and warehouse?

OSHA does not have specific speed limits set for the safe operation of a powered industrial truck. However, in determining what is a safe speed, OSHA would take a variety of factors into consideration. These factors include, but are not limited to, the type of truck, the manufacturer's limitations on the truck, the load being carried, adequate stopping distances, operating surface conditions, pedestrian traffic, and other safety issues.

While specific speed limits are not available, OSHA has said it would consider the totality of the circumstances surrounding the operation of the powered industrial truck in determining whether safe travel speeds are practiced at a workplace. For additional assistance in determining safe travel speeds, OSHA says an employer could look to consensus standards such as ASME B56.1 Safety Standard For Low Lift and High Lift Trucks. For example, paragraph 4.3.2 of ASME B56.1 contains a Stopping Distance formula which may be useful in determining approximate theoretical stopping distances where certain variables are known. This information, along with other factors, can then be used to calculate a maximum safe speed.

Otherwise, the OSHA regulation addresses speeds in a few places, in a general manner:

  • 1910.178(n)(1) - All traffic regulations shall be observed, including authorized plant speed limits. A safe distance shall be maintained approximately three truck lengths from the truck ahead, and the truck shall be kept under control at all times.
  • 1910.178(n)(4) - The driver shall be required to slow down and sound the horn at cross aisles and other locations where vision is obstructed. If the load being carried obstructs forward view, the driver shall be required to travel with the load trailing.
  • 1910.178(n)(7) - Grades shall be ascended or descended slowly.
  • 1910.178(n)(8) - Under all travel conditions the truck shall be operated at a speed that will permit it to be brought to a stop in a safe manner.
  • 1910.178(n)(10) - The driver shall be required to slow down for wet and slippery floors.
  • 1910.178(n)(15) - While negotiating turns, speed shall be reduced to a safe level by means of turning the hand steering wheel in a smooth, sweeping motion. Except when maneuvering at a very low speed, the hand steering wheel shall be turned at a moderate, even rate.

Do powered industrial trucks have to have backup alarms or warning lights?

OSHA does not have a requirement that forklift vehicles be equipped with a backup alarm or warning light (although these features are standard on most new equipment).

A forklift must have, at minimum, some type of sound-producing device that an operator can use at cross aisles and blind intersections where vision is obstructed to warn pedestrians and other forklift drivers that they are approaching. The "sound-producing device" mentioned in the Powered Industrial Truck standard is a horn.

Does OSHA require forklifts to have fire extinguishers?

Federal OSHA does not specifically require employers to equip forklifts with portable fire extinguishers. However, depending on the hazards present in an area where the trucks travel, OSHA may have requirements for fire protection in that specific hazardous location. However, if the manufacturer equips its forklifts with fire extinguishers, the employer must maintain the extinguishers (according to the requirements of 1910.157) and cannot remove/modify the equipment without written permission from the manufacturer. Note: There are various usage options and training requirements in 1910.157 regarding portable fire extinguishers.

Also, the Liquefied Petroleum Gas standard at 1910.110(e)(2) requires that LP-Gas fueled forklifts comply with NFPA 505-1969 Standard for Type Designations, Areas of Use, Maintenance and Operation of Powered Industrial Trucks. Although the 1969 edition does not reference fire extinguishers, the 2006 edition addresses their use in Chapter 9, which states that where either the "authority having jurisdiction" or the end user requires an industrial truck to be equipped with a portable extinguisher, the location of the extinguisher must be in accordance with the truck manufacturer’s recommendation. The NFPA standard also says that industrial trucks can only be equipped with portable extinguishers if operators have been trained in their safe operation and use.

Is there anything in the OSHA standard that references an operator using the blades of a fork truck to push a heavy load with the tips?

If the loads that are being bulldozed result in a hazardous condition because they are not stable or safely arranged, there would be a violation of OSHA’s requirements at §1910.178(o)(1). This work practice is potentially hazardous for the forklift drivers and for any pedestrians who may be in the area. The forklifts also are probably not designed to be used in a bulldozing manner. In addition, §1910.178(l)(3)(i)(M) requires that employees receive training on any operating instructions, warnings, or precautions listed in the operator's manual. If the truck's manual has warnings against these types of practices then this must be included in the training program content.

The manufacturer of our forklift is no longer in business. What do we do about modifications to it?

In a letter of interpretation 04/11/1997 – Powered industrial truck modifications, OSHA stated:" 29 CFR 1910.178(a)(4) requires that 'Modifications and additions which affect the capacity and safe operation shall not be performed by the customer or user without manufacturers prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.' In the event that a powered industrial truck manufacturer has been sold to another company and is no longer in business, the user or customer must contact the purchasing company to request approval. In the event that the original powered industrial truck manufacturer is no longer in business and has not been purchased by another entity, the user or customer would be required to contact a Qualified Registered Professional Engineer for approval of such modifications and additions."

Are we required to mark a powered industrial truck before adding front-end attachments?

A front-end attachment would generally be an "addition" within the meaning of §1910.178(a)(4) that affects capacity and safe operation. Section 1910.178(a)(5) assumes that the truck with the attachments will already be, "marked to identify the attachments and show the approximate weight of the truck and attachment combination at maximum elevation with load laterally centered." However, before a non-factory-installed attachment may be used, the employer must comply both with (a)(4), by obtaining the truck manufacturer’s written approval, and with (a)(5), by having the truck appropriately marked.

Does OSHA have any prohibitions against suicide knob on the steering wheel of forklifts?

The OSHA Powered Industrial Truck regulation does not specifically address steering knobs. However, there is an industry standard that Federal OSHA has often referenced: ANSI/ITSDF B56.1. This industry standard provides some fairly detailed information on steering knobs. (In short, the ANSI standard does allow for steering knobs if certain criteria are met, and in some cases steering knobs may even be necessary, for example when steering must be accomplished with one hand. The equipment operating instructions should also be consulted.

When are wheel chocks required?

In most cases, commercial motor vehicles (CMV) are no longer required to chock trailer wheels when parking at loading docks. In an agreement between the Federal Motor Carrier Safety Administration (FMCSA) and OSHA, authority over CMV parking issues belongs to the FMCSA. Consequently, OSHA’s wheel chocking requirements in 29 CFR 1910.178(k)(1) and 1910.178(m)(7) of the Powered Industrial Truck standard no longer apply to commercial motor vehicles. This applies to any vehicle that:

  • Has a gross vehicle weight rating or gross vehicle weight of at least 10,001 pounds, whichever is greater, or
  • Is designed or used to transport more than eight passengers (including the driver) for compensation, or
  • Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation, or
  • Is used in transporting hazardous material in an amount requiring placarding under DOT regulations.

The FMCSA's parking brake standard, 49 CFR 393.41(a), requires that every commercial motor vehicle manufactured since March 1990 (with the following four exceptions) be equipped with a parking brake system adequate to hold the vehicle or combination under any condition of loading.

However, agricultural commodity trailers, converter dolly, heavy hauler, and pulpwood trailers must carry and use chocking blocks to prevent movement when parked. Section 393.43(d) also requires that the trailer's brakes be applied automatically upon breakaway from the towing vehicle and maintained for at least 15 minutes.

In April 2001, OSHA instructed its regional offices that enforcement personnel are not to cite its wheel chocking requirements at 29 CFR 1910.178(k)(1) or 1910.178(m)(7) with regard to commercial motor vehicles. OSHA is currently developing enforcement guidelines for further clarification.

Can operators wear headphones while operating a forklift?

Although neither OSHA's occupational noise exposure regulation nor the powered industrial truck standard address the use of headphones in the workplace, OSHA has issued Letters of Interpretations that do not recommend the practice. A major concern for a forklift operator is that the operator will increase the volume of the headphones high enough to drown out workplace noise. This can result in the operator not hearing alarms and shouted warnings, as well as exposing him/herself to noise levels that exceed the OSHA permissible exposure levels.

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Definitions

Are safety platforms attached to the forks of a forklift considered aerial lifts?

A platform attached to the forks of a forklift would not be considered an aerial lift. OSHA considers these to be forklifts with personnel platforms attached. While the OSHA standard does not address using personnel platforms with forklifts, the Agency does require that employers obtain manufacturer’s prior written approval, as this is considered to be an addition/modification affecting capacity and safe operation. In addition, fall protection and other measures must be in place to keep those on personnel platforms safe.

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Inspections

How often does a forklift have to be inspected?

OSHA requires that forklift vehicles have to be inspected at least daily, or after each shift when used around the clock. You will find this requirement in the Powered Industrial Truck standard at 1910.178(q)(7).

How long is an employer required to keep forklift daily inspection sheets?

Federal OSHA requires that forklift vehicles have to be inspected at least daily, or after each shift when used around the clock. You will find this requirement in the Powered Industrial Truck standard at 1910.178(q)(7). OSHA does not require that forklift inspections be documented.

However, using an inspection checklist, either written or electronic, is a good idea for two reasons:

  1. You ensure that all essential features of the vehicle are inspected routinely, and
  2. It provides evidence to an OSHA inspector that the vehicles are being inspected as required by 1910.178(q)(7).

Because daily inspection sheets are not required by OSHA, you should keep them according to whichever system works best in your company. Also, as part of your forklift program, it is a good idea to write a company policy stating something like "We retain forklift inspection sheets for six months." That way, you can keep whatever amount you decide, and it also will be proof to OSHA that your company is inspecting the vehicles (without retaining a huge stack of papers).

Note that some state programs might require retention. For example, in California, the daily inspection log can be considered a record of a scheduled inspection to identify unsafe conditions. In California, such records must be retained for one year under Cal/OSHA regulation §3203(b).

How often does the fire extinguisher on the forklift have to be inspected?

OSHA does not require fire extinguishers on forklifts. However, if they are provided they would fall under 1910.157(e), which requires portable fire extinguishers to be visually inspected monthly and subjected to a maintenance check annually.

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Seat Belts

Are there any times when a driver does not have to wear a seatbelt?

OSHA's current policy does not distinguish based on the number of stops. It requires that if seat belts are on the equipment, they must be used at all times while operating.

Must we retrofit our powered industrial trucks with seatbelts if they were not manufactured with them?

Federal OSHA's current enforcement policy on the use of seat belts on forklifts is that employers must require operators of forklifts that are equipped with operator restraint devices, including seat belts, to use the devices. In addition, OSHA may also cite employers who do not take advantage of a manufacturer operator restraint system or seat belt retrofit program. This is all explained in Federal OSHA's 10/09/1996 Seat Belt Policy (corrected in 2007). (Federal OSHA enforces the seat belt issue under the General Duty Clause of the OSH Act; there is not a specific regulation.)

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