Are you ready for an Occupational Safety and Health Administration (OSHA) inspection of your powered industrial truck compliance? In the warehousing and storage industry, the powered industrial truck standard is OSHA’s most frequently cited standard. 

The agency currently has several powered industrial truck regional emphasis programs (REPs), as well as industry-specific REPs for warehousing and storage that include 

inspection procedures and checklists for evaluating forklift safety compliance. 

The agency just launched an REP for warehouse operations in Delaware, the District of Columbia, Pennsylvania, and West Virginia (in Region 3) that focuses on forklift safety, as well as ergonomic and heat hazards. 

The Region 3 REP targets inspections of warehousing, storage, and distribution yard operations of:

  • Bottled and canned soft drink and water producers; 
  • Fluid milk producers; 
  • General warehousing and storage facilities; 
  • Refrigerated warehousing and storage facilities; 
  • Supermarkets and groceries; and 
  • Wholesalers of beer and ale, groceries and related products, and meat and meat products. 

In addition to the ergonomic, heat, and other hazards of warehousing, OSHA’s Region 3 REP is focused on powered industrial truck compliance and includes checks of hazards such as standup forklift under-ride hazards, as well as the maintenance of vehicles, operations and practices, proper charging or fueling procedures, safety rule enforcement, and training. 

There also is an REP for warehousing operations in OSHA’s Region 9—Arizona, California, Hawaii, Nevada, American Samoa, Guam, and the Northern Mariana Islands—that launched in November 2018. 

There is a warehousing and refuse handlers and haulers REP in OSHA’s Region 2—New Jersey, New York, Puerto Rico, and the U.S. Virgin Islands. The Region 2 warehousing and refuse handlers and haulers REP includes inspections for powered industrial truck compliance. 

There also are powered industrial truck emphasis programs in Region 1, Region 4, Region 5, Region 7, and Region 10. While OSHA area offices usually select facilities for forklift compliance under the REPs, agency compliance safety and health officers (CSHOs) may also expand other inspections to include powered industrial truck compliance if they observe powered industrial trucks in use. If an employer refuses to allow a CSHO to expand the scope of an inspection to include powered industrial trucks, then the CSHO will consult with the area director, but the agency may seek a warrant for inspection. 

During inspections, CSHOs will review an employer’s OSHA 300 logs and OSHA 300A summaries for workplace injuries involving forklifts. 

Inspection procedures in the Region 1, 4, 5, 7, and 10 REPs include: 

  • Determining the types of powered industrial trucks in use at the facility or site; 
  • Determining which employees are designated to operate them and operators’ training and experience; 
  • Inspecting powered industrial trucks for potential equipment defects or hazards; 
  • Observing powered industrial truck operations and handling; 
  • Interviewing operators to discuss training, evaluations, incidents and accidents, handling of defective trucks, and repairs; and 
  • Interviewing employers or trainers to discuss training policies and procedures, training programs, frequency of training, determination of competency when hiring experienced operators, evaluation of operators, maintenance and servicing of trucks, knowledge of the owner’s manual, and the removal of defective trucks from service and their return to service. 

Under the regional program directives, CSHOs look at issues that include whether industrial trucks meet industry design standards; supervisors’ awareness of equipment designations; operators’ knowledge of proper powered industrial truck use; fuel handling and storage; changing and charging batteries; proper bridge plates and dock boards; operator training; proper traveling, loading, and operation; and maintenance. 

Industries targeted by the Region 1, 4, 5, 7, and 10 powered industrial truck REPs include agricultural, construction, and maritime industries, as well as general industry. 

Under the Region 5 program, CSHOs will evaluate elements of compliance such as:

  • Equipment and training, 
  • Forklift traffic and speed control, 
  • Ability to turn forklifts or drive in reverse when the mast is elevated, 
  • Blocking or cribbing when a lift is jacked up during maintenance to prevent crushing injuries, 
  • Blocking mast and upright during maintenance to prevent caught-between injuries, 
  • Dock safety programs to prevent struck-by and crushed-by injuries, 
  • Use of an approved lifting platform secured to forks to prevent fall injuries, 
  • Use of appropriate tie-off fall protection for open lifting platforms used in warehouse stocking, and 
  • Lifting carriage amputation protection. 

 Proposed revisions 

OSHA also has a rulemaking to update its powered industrial truck regulations. Updates to the general industry and construction standards proposed February 15 would add references to the latest equipment design and construction requirements published by the American National Standards Institute (ANSI) and the Industrial Truck Standards Development Foundation. 

OSHA’s powered industrial truck standard, which became effective in 1971, is based on ANSI’s 1969 industry consensus standard (ANSI B56.1). ANSI has updated the standard 12 times since—in 1975, 1983, 1988, 1993, 2000, 2004, 2005, 2009, 2012, 2016, 2018, and 2020. 

While ANSI regularly updates its B56 standards, OSHA acknowledged it is difficult for the agency to provide timely corresponding updates in its regulatory standards through the notice and comment rulemaking process. 

The rulemaking would only affect which powered industrial trucks are acceptable for use at a site or facility. 

Compliance checklist 

 OSHA’s powered industrial trucks standard includes provisions covering operator training and certification and safe forklift operation, as well as battery changing and charging, the control of noxious fumes or gases, forklift maintenance, fuel handling and storage, lighting for forklift operational areas, and safety guards. 

Your compliance program needs to address operator training, operation, and maintenance, including the battery changing or charging and fueling of forklifts and other powered industrial trucks. 

You may want to review your compliance using a checklist based on lists OSHA’s regional offices provide agency inspectors: 

  • Do industrial trucks meet the design requirements of ANSI B56.1? 
  • Has the manufacturer provided written approval for any modifications affecting the capacity and safe operations of equipment? 
  • Do industrial trucks on-site have labels designating approval for use in hazardous and/or nonhazardous locations, and are there only approved industrial trucks used in hazardous areas? 
  • Do the storage and handling of liquid fuels meet the requirements of the National Fire Protection Association’s (NFPA) standard for Liquified Petroleum Gases (NFPA 58)? 
  • Are personnel instructed that fuel tanks may not be filled while the engine is running? 
  • Are fuel or oil spills required to be carefully washed away or completely evaporated and the fuel tank cap replaced before restarting the engine? 
  • Are drivers prohibited from operating a truck with a leak in the fuel system until the leak has been corrected? 
  • Is the use of open flames prohibited for checking electrolyte levels in storage batteries or gasoline levels in fuel tanks? 
  • Are there requirements that repairs of industrial truck fuel and ignition systems, which involve fire hazards, only be conducted in locations designated for such repairs? 
  • Is there a requirement that the battery be disconnected before making repairs to a truck’s electrical system? 
  • Are there requirements that industrial trucks not be altered without the manufacturer’s approval? 
  • Is there a requirement for examining an industrial truck before placing it back in service? 
  • Is there a requirement that water mufflers be filled daily or as frequently as necessary to prevent depletion of the water supply below 75 percent of full capacity? 
  • Is there a requirement that vehicles with mufflers and screens or other parts that can become clogged not be operated when screens or parts are clogged? 
  • Are only trained and authorized operators permitted to operate a powered industrial truck? 
  • Is there a requirement that any vehicle emitting hazardous sparks or flames from its exhaust system be removed immediately from service and not be returned to service until the cause of spark or flame emissions has been eliminated? 
  • Is there a requirement that a truck be removed from service when the temperature of any part of the truck exceeds normal operating temperature, creating a hazardous condition, and not be returned to service until the cause of overheating has been eliminated? 
  • Is it prohibited for a person to stand or pass under the elevated portion of any truck, whether loaded or empty? 
  • Are unauthorized personnel prohibited from riding on powered industrial trucks? 
  • Is it prohibited for arms or legs to be placed between the uprights of the mast or outside the running lines of a truck? 
  • Is there a requirement for load-engaging means to be fully lowered, controls neutralized, power shut off, and brakes set when a powered industrial truck is left unattended? 
  • Is it required that personnel maintain a safe distance from the edge of ramps or platforms while on any elevated dock, freight car, or platform? 
  • Is an overhead guard used as protection against falling objects? 
  • Is a load backrest extension used whenever necessary to prevent a load or part of a load from falling backward? 
  • Is there a requirement that all industrial truck traffic regulations be observed, including authorized plant speed limits? 
  • Are drivers required to yield the right of way to ambulances, fire trucks, or other vehicles during emergencies? 
  • Are drivers required not to pass other trucks traveling in the same direction at intersections, blind spots, or other dangerous locations? 
  • Are drivers required to slow down and sound the horn at cross aisles and other locations where vision is obstructed? 
  • Are drivers required to cross railroad tracks diagonally, wherever possible? 
  • Is there a requirement that loaded trucks be driven with a load upgrade when ascending or descending grades that exceed 10 percent? 
  • Is there a requirement on all grades that the load and load-engaging means be tilted back, if applicable, and raised only as far as necessary to clear the road surface? 
  • Are drivers required to operate trucks at a speed that will permit safe stopping under all travel conditions? 
  • Are stunt driving and horseplay prohibited? 
  • Are dock boards or bridge plates properly secured before they are driven over? 
  • Are drivers required to approach elevators slowly and enter squarely after the elevator car is properly leveled? 
  • Are motorized hand trucks required to enter elevators or other confined areas with the load end forward? 
  • Are drivers instructed that only stable or safely arranged loads may be handled? 
  • Are drivers instructed that only loads within the rated capacity of the truck may be handled? 
  • Is a load-engaging means placed under the load as far as possible? 
  • Are drivers required to use extreme care when tilting the load forward or backward, especially when high-tiering?

 

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599. 

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