OSHA TOP TEN CITATIONS

This Month’s Topic – Powered Industrial Trucks 1910.178

This standard is another one where a General Industry Standard is incorporated by reference in the construction standards. Therefore, this same standard applies to both general industry companies and construction companies.
This is one standard where it can be argued that effective training along with management commitment will ensure safety and compliance.
A few basics. A powered industrial truck (PIT) includes:

• Forklifts
• Pallet Jacks (powered)
• Narrow Aisle Trucks
• Rough Terrain Trucks

An earthmoving vehicle modified to accommodate forks (think skid steerer) is not considered a powered industrial truck. While not subject to the standard, please make sure operators of this equipment are trained and use the equipment safely.

PITs are powered by different fuels and are given designations based on the fuel type. LP, gasoline, diesel and electric are the common types. Match the PIT to the operational needs and workplace environment. For example, an electric truck is more suitable to indoor environments where a lack of proper ventilation may lead to carbon monoxide exposure.

By far, lack of training is the leading OSHA citation for the 1910.178 standard. All operators of forklifts must be trained including an evaluation of the operator on the PIT. Training consists of formal “classroom” training that can either be instructor-led, written information, video, computer-based or a verbal discussion. A test should be given to make sure the employee understands the training information.
Specific topics must be covered. These topics are broken down into two categories: Truck-related and Workplace-related.

In addition to the formal training, an employee should receive training on the equipment. This training, under the supervision of an experienced operator or supervisor. The final evaluation of the employee should be conducted by a designated trainer. This person needs to have the experience and knowledge of forklift operations to evaluate the employee’s skills.

Employees must be trained and evaluated on each type of PIT they will operate. Annual refresher training is not required, but refresher training is required when an operator is involved in an accident, near miss or is not operating the truck in a safe manner. Operators must be evaluated every three years and recertified by a qualified trainer. Evaluations can be simply an observation of the operator performing normal work tasks.
An important part of training is to instruct operators on how to do an inspection. Pre-shift inspections of forklifts are required. Operators must know to report unsafe conditions immediately so they can be corrected. Those performing inspections must have confidence that management will take appropriate actions to deal with deficiencies found in inspections. Operators should not be expected to compensate for unsafe equipment.
Tip overs are a common cause of fatalities and for that reason, operators must be instructed to use the seatbelt. If the truck does not have a seatbelt, but one can be installed, we recommend that it be installed.

No modifications that can affect the capacity or operation of the PIT may not be done without the manufacturer’s approval. OSHA takes this one seriously. The agency recently cited a company with a willful violation for modifying a forklift. An employee was struck and killed by a 40,000 lb. coil at a marine terminal. The company added a ram to move coils. The addition of the ram affected capacity and operator vision and was not approved by the manufacturer. The company was penalized $70,000 for that violation.

Another important area of safety regards pedestrians and those who work around powered industrial trucks. Operators need to be trained to look behind immediately before backing and must use the horn when traveling around a corner or through intersections.
Forklift safety and OSHA compliance will be achieved when there is an effective training program in place and when management supports the program.