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Subpart N 1910.178 Powered Industrial Trucks

Mary Bauer CIH, CSP Compliance Assistance Specialist

Eau Claire, WI 54701

715-832-9019

WABA

July 15, 2015

Wisconsin Dells, WI

MY BACKGROUND

Mary Bauer

30 years w/ OSHA

IH/ Safety

CIH: Certified Industrial Hygienist

CSP: Certified Safety Professional

1000 + Inspections

NUMBER OF SERIOUS VIOLATIONS – FY 2014

29

CFR

19

10

SU

BPA

RTS

MATERIALS HANDLING & STORAGE [1910.176 – 184]

3

SUB

PAR

T N

257

305

339

418

590

178(q)(7)

178(p)(1)

178(l)(6)

178(l)(4)(iii)

178(l)(1)(i)POWERED INDUSTRIAL TRUCKS – COMPETENCY TRAINING

POWERED INDUSTRIAL TRUCKS – REFRESHER TRAINING IN RELEVANT TOPICS

POWERED INDUSTRIAL TRUCKS – CERTIFICATION OF TRAINING

POWERED INDUSTRIAL TRUCKS – SAFE OPERATING CONDITION

POWERED INDUSTRIAL TRUCKS – EXAMINATION FOR DEFECTS

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Definition - Powered Industrial Truck

American Society of Mechanical Engineers

(ASME B56.1 Formerly ANSI B56.1 standard)

“Mobile, powered truck used to carry, push, pull, lift, stack, or

tier material”

WHAT IS NOT A CRANE (NOT INCLUDED IN

THE CONSTRUCTION CRANE STANDARD)?

Tow trucks*

Vehicle mounted

work platforms

Self-propelled

elevating work

platforms

Stacker cranes

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FORKLIFTS ARE NOT CRANES OR JACKS!

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Class I - Electric Motor Rider Trucks

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Class I - Electric Motor Rider Trucks

• Counterbalanced

Rider Type, Stand-Up

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Class III - Electric Motor Hand or Hand/Rider Trucks

• Low lift platform

• Low lift walkie pallet

• Reach type outrigger

• High lift straddle

• High lift counterbalanced

• Low lift walkie/rider pallet

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Class III - Electric Motor Hand or Hand/Rider Trucks

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Class III - Hand & Hand/Rider Trucks

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Class IV - Internal Combustion Engine Trucks - Cushion (Solid) Tires

Fork, counterbalanced (cushion/solid tires)

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Class IV - Internal Combustion Engine Trucks - Cushion (Solid) Tires

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Class V - Internal Combustion Engine Trucks - Pneumatic Tires

Fork, counterbalanced (pneumatic tires)

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Class V - Internal Combustion Engine Trucks (Pneumatic Tires)

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Class VI - Electric & Internal Combustion Engine Tractors

Sit-down rider

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Class VII - Rough Terrain Forklift Trucks

Straight-mast forklift Extended-reach forklift

All rough terrain forklift trucks

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Rough Terrain Straight Mast Forklifts

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Rough Terrain Extended-Reach

Forklifts

Modifications and additions

which affect capacity and safe

operation shall not be

performed by the customer or

user without manufacturer’s

prior written approval. Capacity,

operation, and maintenance

instruction plates, tags, or

decals shall be changed

accordingly.

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1910.178(a)(4) Modifications

Must get manufacturer’s

approval for modification

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Do not load

the ends of

the forks

If the truck is equipped with

front-end attachments other

than factory installed

attachments, the user shall

request that the truck be

marked to identify the

attachments and show the

approximate weight of the

truck and attachment

combination at maximum

elevation with load laterally

centered.

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1910.178(a)(5)

ID - Attachments

Show Weight Combo

Max Elevation

The user shall see that all nameplates and markings are in place and are maintained in a legible condition.

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1910.178(a)(6)

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As used in this section, the term, "approved

truck" or "approved industrial truck" means a

truck that is listed or approved for fire safety

purposes for the intended use by a nationally

recognized testing laboratory, using nationally

recognized testing standards. Refer to

1910.155(c)(3)(iv)(A) for definition of nationally

recognized testing laboratory.

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1910.178(a)(7)

(1) High Lift Rider trucks

shall be fitted with an

overhead guard

manufactured in

accordance with

paragraph (a) (2) of this

section, unless operating

conditions do not permit.

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1910.178(e) Safety guards

Lacks Overhead

Guard

(1) Battery charging installations

shall be located in areas

designated for that purpose.

(2) Facilities shall be provided for

flushing and neutralizing spilled

electrolyte, for fire protection, for

protecting charging apparatus from

damage by trucks, and for

adequate ventilation for dispersal

of fumes from gassing batteries.

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1910.178(g) Changing and charging storage batteries

Battery Charging

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Designated Battery Charging Area 1910.178(g)(2)

Adequate Ventilation

1910.178(g)(2)(10)&(11) Fire Protection

1910.157(c) Safety Showers

Eye Wash

1910.178(g)(8) Brake Set

Properly Positioned

Where general

lighting is less than 2

lumens per square

foot, auxiliary

directional lighting

shall be provided on

the truck.

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1910.178(h)(2) - Lighting

1 candle source = 12.57 lumens

(1) Concentration levels of carbon monoxide

gas created by powered industrial truck

operations shall not exceed the levels

specified in 1910.1000.

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1910.178(i) Control of noxious gases and fumes

50 PPM

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ACUTE EXPOSURE

Headache

Nausea

Weakness

Irritability

Chest Pain

Unconsciousness

CHRONIC EXPOSURE

Headache

Dizziness

Anorexia

Ataxia

Confusion

FORKLIFT EXHAUST TEST

Not Required by

Federal OSHA but

indicator of

problems.

MN State Law

Often tested by

service companies

< 1%

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(1) The brakes of highway trucks shall

be set and wheel chocks placed under

the rear wheels to prevent the trucks

from rolling while they are boarded with

powered industrial trucks.

(2) Wheel stops or other recognized

positive protection shall be provided to

prevent railroad cars from moving during

loading or unloading operations.

A safe distance shall be maintained

from the edge of ramps or platforms

while on any elevated dock, or platform

or freight car. Trucks shall not be used

for opening or closing freight doors.

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(k) Trucks and railroad cars

Wheel chocks

(3) Fixed jacks may be

necessary to support a

semitrailer and prevent

upending during the

loading or unloading when

the trailer is not coupled

to a tractor.

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(k) Trucks and railroad cars

Jacks - Prevent upending

(4) Positive protection

shall be provided to

prevent railroad cars

from being moved

while dockboards or

bridge plates are in

position.

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(k) Trucks and railroad cars

Prevent movement of rail cars

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1910.178(n)(11) Dockboard or bridgeplates, shall be properly secured before they are driven

over. Dockboard or bridgeplates shall be driven over carefully and slowly and their rated

capacity never exceeded.

1910.178(k)

Fixed Jacks

1910.178(k)(1)

Wheel Chocks

1910.30(a)

1910.178(j)

1910.178(n)(11)

Dockboard/Bridge Plates

Maintenance of dock plates and levelers can be hazardous – A safety bar (lockout device) may be needed. Access to dock door area should be restricted (e.g., cones, guard rails or other barrier).

Best Safety Practice: Have a place for drivers to wait. No “Live Loading”

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Trailer “Deadlining” with a lockout device Lock is applied to emergency brake, and must be removed before airline can be connected Prevents driver from pulling away before employees are clear Dock supervisor or forklift operator has custody of key

(3) Unauthorized

personnel shall not be

permitted to ride on

powered industrial trucks.

A safe place to ride shall

be provided where riding

of trucks is authorized.

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1910.178(m) Truck operations

A SAFE PLACE TO RIDE

IS REQUIRED

(i) When a powered industrial truck is left

unattended, load engaging means shall be

fully lowered, controls shall be neutralized,

power shall be shut off, and brakes set.

Wheels shall be blocked if the truck is

parked on an incline.

(ii) A powered industrial truck is

unattended when the operator is 25 ft. or

more away from the vehicle which remains

in his view, or whenever the operator

leaves the vehicle and it is not in his view.

(iii) When the operator of an industrial

truck is dismounted and within 25 ft. of

the truck still in his view, the load

engaging means shall be fully lowered,

controls neutralized, and the brakes set to

prevent movement.

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1910.178(m)(5) Truck Operations

Unattended Truck

(ii) A powered industrial

truck is unattended when

the operator is 25 ft. or

more away from the

vehicle which remains in

his view, or whenever the

operator leaves the

vehicle and it is not in his

view.

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An overhead guard shall be

used as protection against

falling objects.

NOTE:An overhead guard is

intended to offer protection 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.

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1910.178(m)(9) Overhead Safety Guard

Whenever a truck is equipped with

vertical only, or vertical and horizontal

controls elevatable with the lifting

carriage or forks for lifting personnel,

the following additional precautions

shall be taken for the protection of

personnel being elevated.

(i) Use of a safety platform firmly

secured to the lifting carriage and/or

forks.

(ii) Means shall be provided whereby

personnel on the platform can shut off

power to the truck.

(iii) Such protection from falling objects

as indicated necessary by the

operating conditions shall be provided.

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1910.178(m)(12) Lifting Personnel

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What do the standards require???

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1910.178(m)(12) Elevatable platform

Approved work basket

Safety Chains

Level Surface

Barricade

Section 5(a)(1) - ANSI B-56.1

PERSONNEL ELEVATING PLATFORMS

Good Platform must

include guardrails

Secure the platform to

the forklift.

Screen at forklift side

PERSONNEL ELEVATING PLATFORMS

OSHA 5(a)(1) Violations

ANSI/ITSDF B56.1-2005:

No screen (scissor point)

Cannot be secured to forks

or backrest

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(3)Other trucks traveling in the same direction at intersections,

blind spots, or other dangerous locations shall not be passed.

(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.

(5) Railroad tracks shall be crossed diagonally wherever possible.

Parking closer than 8 feet from the center of railroad tracks is

prohibited.

(6) The driver shall be required to look in the direction of, and keep

a clear view of the path of travel.

(9) Stunt driving and horseplay shall not be permitted.

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1910.178(n)Traveling

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(1) Only stable or safely

arranged loads shall be

handled. Caution shall be

exercised when handling off-

center loads which cannot be

centered.

(2) Only loads within the rated

capacity of the truck shall be

handled.

(3) The long or high (including

multiple-tiered) loads which

may affect capacity shall be

adjusted.

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1910.178(o) Loading

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(1) 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.

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1910.178(p) Operation of the truck

Take out of service

Industrial trucks shall be

examined before being placed in

service, and shall not be placed

in service if the examination

shows any condition adversely

affecting the safety of the

vehicle. Such examination shall

be made at least daily.

Where industrial trucks are used

on a round-the-clock basis, they

shall be examined after each

shift.

Defects when found shall be

immediately reported and

corrected.

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1910.178(q)(7) Examination of Trucks

Examination

INSPECTIONS

Per manufacturer’s guidelines.

At least daily before use.

Check all working components and safety device.

Address all leakage of fluids.

Search for defective hydraulic/pneumatic hoses.

Look for quickfix signs (not acceptable) i.e. electrical tape, rags tied on hoses…

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INSPECTIONS

Why is this inspection form weak?

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RESTRAINTS OR SEAT BELTS

“OSHA's enforcement policy on the use of seat

belts on powered industrial trucks is that

employers are obligated to require operators of

powered industrial trucks that are equipped

with operator restraint devices, including seat

belts, to use the devices.”

Enforcement of the Use of Seat Belts on Powered

Industrial Trucks in General Industry October 9,

1996:

SEATBELTS

Must be worn when

equipped.

Prevent the operator from

being pinned by the truck or

overhead guard.

Must install if retrofit is

available Click for rollover video

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INSPECTION

Labels

Ensure that

capacities for

attachments

are listed

INSPECTION

Load Backrest

Extension is damaged

INSPECTION

How much wear is

acceptable?

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FORKLIFT INSPECTIONS

Overhead guard

improperly welded

FORKLIFT INSPECTION

Broken Fiberglass

Housing is a Laceration

Hazard

INSPECTION

Leaking Hydraulic Fluid

Can lead to:

Low pressure

Air bubbles

Erratic operation

Slippery surfaces

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LP TANK ORIENTATION: PRESSURE RELIEF VALVE AT

THE 12:00 POSITION

Slot/Hole Correctly Placed on Locator Pin

Slot/Hole not Place on Locator Pin

If the valve operates, the vapor will

come out and not the liquid

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1910.178(l) Operator training.

(i) The employer

shall ensure that

each powered

industrial truck

operator is

competent to

operate a powered

industrial truck

safely

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1910.178(l)(1) Safe operation.

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Prior to permitting an

employee to operate a

powered industrial truck

(except for training

purposes), the employer

shall ensure that each

operator has successfully

completed the training

required by this

paragraph (l), except as

permitted by paragraph

(l)(5).

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1910.178(l)(1)(ii) Prior to permitting employee to operate PIT

Ensure successful

completion of training

(i) Trainees may operate a powered

industrial truck only:

(A) Under the direct

supervision of persons who

have the knowledge, training,

and experience to train

operators and evaluate their

competence

(B) Where such operation does

not endanger the trainee or

other employees.

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1910.178(l)(2) Training program implementation.

Trainees may operate under direct supervision

Combination - formal

instruction (e.g., lecture,

discussion

interactive computer learning

video tape

written material)

Practical training

demonstrations performed by

the trainer and practical

exercises performed by the

trainee), and evaluation of the

operator's performance in the

workplace.

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1910.178(l)(2)(ii) Training shall consist of:

Combination of ways to train

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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.

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1910.178(l)(2)(iii) Trainer

An evaluation of each powered industrial truck operator's performance shall be

conducted at least once every three years.

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1910.178(l)(4)(iii) Evaluation

If an operator has previously received training in

a topic specified in paragraph (l)(3) of this

section, and such training is appropriate to the

truck and working conditions encountered,

additional training in that topic is not required if

the operator has been evaluated and found

competent to operate the truck safely.

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1910.178(l)(5) Duplication of training

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The employer shall certify that

each operator has been

trained and evaluated as

required by this paragraph (l).

The certification shall include

the name of the operator, the

date of the training, the date of

the evaluation, and the identity

of the person(s) performing

the training or evaluation.

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1910.178(l)(6) Certification.

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Certification • The employer shall certify that each

operator has been trained and

evaluated as required by the standard.

• Certification shall include:

– Name of operator

– Date of training

– Date of evaluation

– Identity of person(s) performing the

training or evaluation

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Training Program Content

• Operators shall receive initial training in

the following topics, except in topics

which the employer can demonstrate are

not applicable to safe operation in the

employer’s workplace.

– Truck-related topics

– Workplace-related topics

– The requirements of the standard

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Training Program Content (continued)

– Operating instructions, warnings and precautions

– Differences from automobile

– Controls and instrumentation

– Engine or motor operation

– Steering and maneuvering

– Visibility

Truck-related topics

– Fork and attachment adaptation, operation, use

– Vehicle capacity and stability

– Vehicle inspection and maintenance that the operator will be required to perform

– Refueling/Charging/ Recharging batteries

– Operating limitations

– Other instructions, etc.

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Training Program Content (continued)

– Surface conditions

– Composition and stability of loads

– Load manipulation, stacking, unstacking

– Pedestrian traffic

– Narrow aisles and restricted areas

– Operating in hazardous (classified) locations

– Operating on ramps and sloped surfaces

– Potentially hazardous environmental conditions

– Operating in closed environments or other areas where poor ventilation or maintenance could cause carbon monoxide or diesel exhaust buildup

Workplace-related topics

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Training Program Content (continued)

• The requirements of the

OSHA standard on powered

industrial trucks must also be

included in the initial operator

training program.

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Refresher Training and Evaluation

• Refresher training, including an evaluation of

the effectiveness of that training, shall be

conducted to ensure that the operator has the

knowledge and skills needed to operate the

powered industrial truck safely.

• Refresher training required when:

– Unsafe operation

– Accident or near-miss

– Evaluation indicates need

– Different type of equipment introduced

– Workplace condition changes

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Refresher Training and Evaluation (continued)

• An evaluation of each powered

industrial truck operator’s

performance must be

conducted:

–After initial training,

–After refresher training, and

–At least once every three years

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Avoidance of Duplicative Training

• If an operator has previously

received training in a topic specified

in this section, and the training is

appropriate to the truck and working

conditions encountered, additional

training in that topic is not required

if the operator has been evaluated

and found competent to operate the

truck safely.

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Unique Characteristics of Powered Industrial Trucks

• Each type of powered industrial

truck has its own unique

characteristics and some inherent

hazards.

• To be effective, training must

address the unique characteristics

of the type of vehicle the employee

is being trained to operate.

SKID STEER

MUSTANG

PIN ON EACH SIDE-INSTALL INSIDE CAB

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EMERGENCY RESPONSE

What is the response

if the drum contains

flammable or toxic

liquid?

WAREHOUSING - STORAGE AREA

Pallet Racking

Damage

Design

Compatible Parts

Anchorage

Weight Rating

ANSI Standard

OSHA ENFORCEMENT

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Effective Powered Industrial Truck Operator Training Program

• Four major areas of concern must be

addressed:

– The general hazards that apply to the

operation of all or most powered industrial

trucks;

– The hazards associated with the operation of

particular types of trucks;

– The hazards of workplaces generally; and,

– The hazards of the particular workplace

where the vehicle operates.

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WAGE & HOUR REFERRAL

No one under 18 allowed on a PIT

“Order 7 of Hazardous Occupations” prohibits employees

under 18 years of age from operating forklifts, employers must

make certain that workers under 18 years of age are not

permitted to use PIT’s.

SUMMARY

All Operators Must Be Trained

OSHA Standards are “Minimum” Training

Best Practices Include:

Written Test, Inspection Records, Evaluations

Frequent Observations

Focus on Highest Risk Areas: Kaizen Events

Human Performance Factors

QUESTIONS QUESTIONS

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DISCLAIMER

This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics or hazards, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.