Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine compliance with powered industrial truck safety standards.
You need to be mindful of the hazards posed by forklifts and other powered industrial trucks and federal enforcement efforts focused on those hazards.
The Occupational Safety and Health Administration (OSHA) recently cited a Nebraska meat processor following an amputation injury involving a forklift. The agency proposed that the employer pay a nearly $275,000 OSHA fine.
A worker’s fingertip got caught in a forklift attachment while helping a forklift operator position materials at the facility—an injury that resulted in a medically necessitated amputation three weeks later.
After its investigation, OSHA determined that the employer failed to provide training for forklift operators and evaluate operators’ competence. OSHA also found that employees were exposed to chemical burns because they weren’t supplied with spill kits for flushing and neutralizing spills while servicing forklift batteries—a violation of the powered industrial trucks standard. Also, employees servicing batteries poured water into batteries containing acid instead of pouring acid into water.
OSHA’s powered industrial trucks standard (29 Code of Federal Regulations (CFR) §1910.178) is one of the agency’s top 10 most cited standards. In fiscal year 2023, it was the fifth most cited standard, cited 2,561 times.
Do you have forklifts or other powered industrial trucks in your facility? Are your equipment, policy, procedures, and training in compliance?
OSHA has several enforcement directives on powered industrial trucks or their use in warehousing operations. The agency currently has regional emphasis programs (REP) for powered industrial trucks in Region 1, Region 4, Region 5, Region 7, Region 8, and Region 10. The agency also has a National Emphasis Program (NEP) for warehousing and distribution center operations, a Region 3 REP for warehousing operations, and a Region 9 REP for powered industrial vehicles and warehousing operations.
Under the warehouse and distribution center NEP, OSHA inspectors conduct comprehensive safety inspections focused on hazards related to powered industrial vehicle operations, including struck-by, caught-in, and caught-between hazards, as well as material handling and storage, walking and working surfaces, means of egress, and fire protection. Workplaces targeted by the NEP also include retail establishments with high injury rates in storage and loading areas.
Warehouses and distribution centers have seen tremendous growth in the past 10 years, according to OSHA, employing more than 1.9 million workers. Injury and illness rates in warehouses and distribution centers are higher than in private industry overall and sometimes more than twice the rate for private industry.
While the powered industrial trucks standard is the most frequently cited standard in warehouse inspections, other frequently cited standards include hazard communication, exit routes, and materials handling.
Powered industrial truck standard
The powered industrial truck standard includes requirements for 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.
Forklifts can pose an injury hazard to their operators, as well as other workers in a facility. Operators must wear a safety belt or restraint if the forklift is equipped with one.
Fatal forklift incidents have included forklift overturns, workers being struck by a forklift, workers being crushed by a forklift, and falls from a forklift, according to the National Institute for Occupational Safety and Health (NIOSH).
NIOSH recommends that operators of sit-down-type forklifts use provided operator restraints. Operators need to know they can be crushed by the overhead guard or another part of the truck if they jump from an overturning forklift.
The institute also recommends making every effort to alert workers when a forklift is nearby, using horns, audible backup alarms, and flashing lights to warn workers and other forklift operators in the area. Flashing lights may be the best way to alert others to a forklift’s presence where the ambient noise level is high.
Forklift operators must be trained and licensed. NIOSH recommends developing a training program with a timetable for refresher training. Employers also need to regularly reevaluate their training programs.
Operators should stay with the truck if a lateral or longitudinal tipover occurs, hold on firmly, and lean away from the point of impact.
Warehousing and storage employers need to separate forklift traffic from other workers wherever possible, limiting some aisles to forklifts only or workers on foot only. Also, restrict forklift use near time clocks, break rooms, cafeterias, and main exits, particularly when the flow of workers on foot is at a peak, like at the end of a shift or during breaks.
You also need to evaluate intersections and blind corners to determine whether overhead dome mirrors could improve visibility for forklift operators or workers on foot.
Forklift operators should never exceed the forklift’s rated load and never lift or lower loads while traveling. They also must be aware of other vehicles, watch for workers on foot, and use horns at cross aisles and in areas with obstructed views. Additionally, they need to have clear visibility of the work area and ensure they have enough clearance when raising, loading, and operating the forklift.
Two years ago, NIOSH examined the death of a forklift operator who was crushed by a pallet full of soft drink cans. In a Fatality Assessment and Control Evaluation (FACE) report, investigators looked at how a 47-year-old forklift operator in Oregon was crushed by a loaded pallet of soft drink cans weighing approximately 2,000 pounds.
The warehouse’s inventory management system incorrectly directed the operator to pull pallets from a row that didn’t contain any product. The operator pulled four pallets from the back of an adjoining row, destabilizing the top layer of pallets.
While cleaning up cases that fell off one of the pulled pallets, the top layer pallet fell onto the operator from a height of approximately 20 feet, causing massive internal injuries.
Factors contributing to the worker’s fatality included fatigue due to a lack of sleep—the forklift operator worked approximately 70 hours a week, working the swing shift full time at the warehouse, as well as another job that started at 6 a.m.—and pallet retrieval procedures that weren’t followed while working under and/or adjacent to a live load.
Your compliance program, OSHA inspections
Any forklifts or other powered industrial trucks in your facility must meet industry consensus standards, and your compliance program needs to address operator training—only trained and authorized operators may be permitted to operate a powered industrial truck. Unauthorized personnel must be prohibited from riding on powered industrial trucks.
The OSHA standard also contains requirements for vehicle operation, maintenance, and repairs, including battery changing or charging and the fueling of powered industrial trucks.
During an inspection under one of the REPs, OSHA personnel will begin by reviewing your OSHA 300 logs and OSHA 300A summaries for workplace injuries involving forklifts. During the facility walkaround, most inspectors will be working off a checklist from an REP directive or one provided by their area office. It helps to be mindful of the issues OSHA’s inspectors will check.
Your industrial trucks must meet the design requirements of American National Standards Institute (ANSI) B56.1. OSHA’s standard, which became effective in 1971, was based on the 1969 version of ANSI’s B56.1 standard.
Moreover, the storage and handling of liquid fuels must meet the requirements of the National Fire Protection Association’s (NFPA) standard for Liquified Petroleum Gases (NFPA 58). Personnel who fuel your industrial trucks must be instructed not to fill fuel tanks while the engine is running. The use of open flames to check gasoline levels in fuel tanks or electrolyte levels in storage batteries must be prohibited, as well.
Fuel or oil spills must be carefully washed away or completely evaporated and the fuel tank cap replaced before restarting the engine.
The repair of industrial truck fuel and ignition systems that may involve fire hazards must only be conducted in locations designated for such repairs. The battery must be disconnected before making repairs to a truck’s electrical system. Following repairs, an industrial truck must be examined before placing it back into service.
Drivers must be prohibited from operating a truck with a leak in the fuel system until the leak has been corrected. They also must not operate vehicles with mufflers, screens, or other parts that have become clogged. Any vehicle emitting hazardous sparks or flames from its exhaust system should be removed from service immediately and not be returned to service until the cause of spark or flame emissions has been eliminated.
A truck must be removed from service when the temperature of any part of the truck exceeds normal operating temperature, which can create a hazardous condition. Trucks must not be returned to service until the cause of overheating has been eliminated.
The industrial truck’s manufacturer must provide written approval for any modifications that would affect the capacity or safe operation of the equipment. Industrial trucks must have labels designating approval for their use in hazardous and/or nonhazardous locations—only approved industrial trucks may be used in hazardous areas.
Federal compliance safety and health officers (CSHO) also may ask a series of questions about powered industrial truck operation in your facility. These include:
- 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 locations where vision is obstructed?
- Are drivers required to cross railroad tracks diagonally wherever possible?
- 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’re driven over?
- Are drivers required to approach elevators slowly and enter squarely after the elevator car is properly leveled?
- 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?
Keep in mind that the powered industrial trucks standard is one of the agency’s most cited and that OSHA has several enforcement programs focused on powered industrial truck hazards.