OSHA 1910.178 - Powered Industrial Trucks

SCOPE AND APPLICATIONMaterial handling is a significant safety concern and injuries and property damage can occur if proper procedures are not used. OSHA requires that all employers using powered industrial trucks implement a program in accordance with OSHA 29 CFR 1910.178. For the purpose of compliance with OSHA standards, this program applies to all powered industrial vehicles, including forklifts, order pickers, reach trucks, and electrically powered pallet jacks.

Only trained and authorized personnel are allowed operate powered industrial trucks. Authorized individuals are those who have completed training at (client name) on the equipment they are to operate.

Our Powered Industrial Vehicle Program contains the following elements:

• Assignment of Responsibilities

• Operator Training

• Pre-Use Inspections

• Operating Procedures

• Maintenance Procedures

• Fueling Procedures

• Program Audit

• Recordkeeping

These are described in detail below.

ASSIGNMENT OF RESPONSIBILITIESManagement Responsibilities

• Provide equipment that is safe to operate

• Not allow modifications to equipment except those authorized by the equipment manufacturer

• Ensure adequate operator safety training is provided on all equipment used to move materials

• Establish and enforce safe operating rules and procedures

The Program Administrator for our Powered Industrial Vehicle Program is:

The Program Administrator will:

• Ensure equipment is safe to operate

• Not allow modifications to equipment except those authorized by the equipment manufacturer

• Ensure proper powered industrial vehicles/forklift training is provided and certify that each operator was trained and evaluated

• Establish and enforce safe operating rules and procedures

• Conduct an annual review of the program

OSHA 1910.178 - Powered Industrial Trucks

Supervisor Responsibilities

• Designate and identify employees responsible for operating powered industrial vehicles

• Monitor the safe operation of the powered industrial equipment

• Ensure that no employees under their direction operate a powered industrial vehicle/forklift without proper certification

• Ensure that operator retraining is conducted when appropriate

• Ensure that all equipment is inspected daily

• Ensure that any damaged equipment is tagged “out of service” or otherwise made inoperable

• Ensure that equipment is repaired when malfunctioning

Employee Responsibilities

• Operate only the equipment for which they were specifically trained and authorized

• Conduct required daily pre-use inspections

• Report any equipment damage or other unsafe conditions affecting the safe operation of the equipment

• Attend applicable training sessions

• Follow all safety rules and operating procedures

OPERATOR TRAININGTrain employees prior to operating the vehicles in the workplace. Training will consist of a combination of formal instruction and practical training. Practical training includes a demonstration performed by the trainee to show their proficiency operating the vehicle. Conduct all operational training and evaluation under close supervision. Successfully complete all training and evaluation before an operator is permitted to operate the vehicle without continual and close supervision.

(Client name) will certify that each operator was trained and evaluated. The certification includes 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.

If an operator previously received training that is relevant to the vehicle and working conditions encountered, additional training is not required if the operator was evaluated and found competent to operate the vehicle safely.

(Client name) will provide the hands-on skills evaluation to ensure operator competency and safe operating procedures are followed.

Prior to completing operator training, the trainee may operate a vehicle only:

• Under the direct supervision of a person selected by management who has the knowledge, training, and experience to evaluate their competence.

• Where the operation of the vehicle does not endanger the trainee or other employees.

Annual retraining is not required. Conduct an evaluation of the operator’s driving performance at least every three years and after refresher training when appropriate. Refresher training is required when:

• The operator was observed operating a vehicle in an unsafe manner.

• The operator was involved in an accident or near miss.

• The operator received an evaluation indicating that he or she is not operating the vehicle safely.

• The operator is assigned to drive a different type of vehicle.

• A condition in the workplace changes in a manner that could affect safe operation of the vehicle.

OSHA 1910.178 - Powered Industrial Trucks

TRAINING PROGRAM CONTENTThe contents of the training session include information on the characteristics of the powered industrial vehicle the employee will operate and the characteristics of the environment in which the vehicle is operated. Employess must also be trained in the requirements of 29 CFR 1910.178 (l).

The following information is covered in the training session.

Characteristics of the vehicle the employee is allowed to operate

• Operating instructions, warnings, and precautions

• Differences between an automobile and the powered industrial vehicle

• Location and function of the controls and instrumentation

• Engine or motor operation

• Steering and maneuvering

• Visibility

• Operation and limitations of the forks and/or attachments

• Vehicle capacity and stability

• Vehicle inspection and maintenance procedures

• Refueling or charging/recharging batteries

• Operating limitations

• Safety equipment

• Any other operating instructions, warning, or precautions listed in the operator’s manual

The operating environment

• Floor surfaces and/or ground conditions where the vehicle is operated

• Composition of probable loads and load stability

• Load lifting, stacking, and unstacking

• Traveling with a load

• Pedestrian traffic

• Narrow aisle and restricted space operation

• Operating in hazardous locations

• Operating the vehicles on ramps or other sloped surfaces that would affect their stability

• Operating the vehicle when driving into a trailer including the proper use of dock plates/ramps, trailer safety, and choking/blocking the trailer wheels

• Other unique or potentially hazardous environmental conditions that exist or may exist in the workplace

• Operating the vehicle in closed environments and other areas where insufficient ventilation and/or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust

The evaluator conducting the operator assessment will use the appropriate evaluation form(s) in Appendix C, D or E.

OSHA 1910.178 - Powered Industrial Trucks

PRE-USE INSPECTIONSInspect all powered industrial vehicles prior to use. Perform the inspection at least daily. When powered industrial vehicles are used on a round-the-clock basis, the inspection must occur at the start of each shift. If the operator finds a defect, the operator must report the problem(s) immediately to their supervisor. In general, the following items are included in the pre-use inspection:

• Check all fluid levels/pressures

• Leaks

• Steering

• Brakes

• Fuel/battery level

• Tires

• Hoses/belts/cables

• Horns/alarms

• Mast/forks

• Gauges/controls

• Overhead cage

Document each inspection, using the inspection check list located in either Appendix A or Appendix B. If unsafe conditions are noted during the inspection, remove that vehicle from use until the deficiencies are corrected.

OPERATING PROCEDURESThe proper way to mount and dismount a forklift is to face the truck and use a three-point stance with two hands on the truck and one foot in contact with the floor or truck at all times. Never jump on or off the forklift.

Become familiar with the location and function of all controls. Controls may vary from unit to unit. If the forklift is equipped with a seat belt, the operator must wear the seatbelt while operating the vehicle. This is an important safety feature that will protect the operator in case of an accident.

Picking up a Load

• Make sure the load does not exceed the capacity of the forklift.

• Make sure the forks are positioned properly.

• Make sure the load is balanced and secure.

• Check for overhead obstructions.

• Raise the forks to the proper height.

• Drive into the load as far as possible.

• Tilt the load back slightly and then lift it.

• Back up (look over both shoulders before backing up) and lower the load two to four inches from the floor before moving.

OSHA 1910.178 - Powered Industrial Trucks

Traveling with a Load

• Pedestrians always have the right-of-way.

• Never allow anyone to ride on the forklift.

• If the load blocks or obscures vision, drive the vehicle backwards to ensure that there is a clear field of vision.

• Keep the forks low, two to four inches above the floor if possible.

• Keep the load tilted back slightly.

• Always drive at a safe speed, and slow down when going around corners.

• Sound the horn when approaching aisles and corners.

• Always drive up and back down ramps and inclines.

• Avoid sudden braking.

• Lift or lower the load only when completely stopped, never when traveling.

Placing a Load

• Stop the forklift completely before raising the load.

• Move slowly with the load raised.

• Never walk or stand under a raised load.

• Tilt the load forward, only when over a stack or rack.

• Be certain the forks clear the pallet before turning or changing height.

• Always stack the load square and straight.

• Before backing, check behind and on both sides for pedestrians or other traffic.

• Unusually shaped loads, such as rolls, may require special stacking. Be aware of the requirements before picking up these loads.

Entering a Trailer, Truck, or Railcar

• Employees are prohibited from driving a vehicle into a trailer, truck, or railcar unless authorized and trained to do so.

• Before entering a trailer, truck, or railcar, make sure the brakes are set. Place wheel chocks at both rear wheels to prevent movement of the trailer away from the dock. Chocks should always be used on the trailers regardless of the status of the truck.

• Before driving into a trailer or truck, check the deck of the trailer for signs of weakness or breakage.

• Use dock board/dock plate or dock leveling devices for safe access into the trailer.

• Check to see that the load and the powered industrial truck mast clear trailer/railcar before attempting to enter.

• If the trailer is not secured to a tractor, make sure the trailer jacks are secured at the front corners of the trailer to prevent upending or corner dipping.

• If dock locks or other fixed trailer restraining equipment is used, make sure it is fully engaged before entering the trailer.

OSHA 1910.178 - Powered Industrial Trucks

UNATTENDED VEHICLESA powered industrial vehicle is considered unattended when the operator is 25 feet or more from the vehicle (when the vehicle remains within the view of the operator) or whenever the operator leaves the vehicle and it is not in the operators’ view.

When a vehicle is unattended:

• Turn off the engine

• Remove and secure the keys

• Fully lower the forks

• Put the vehicle in neutral or park

• Apply the parking brake

• Turn the propane cylinder valve off

MAINTENANCE PROCEDURESRepairs:

• Remove any powered industrial truck/forklift truck not in a safe operating condition from service. Only authorized personnel utilizing lockout/tagout procedures are permitted to repair industrial trucks/forklifts.

• Conduct repairs to the fuel and ignition systems which involve fire hazards only in designated locations for such repairs.

• Replace all parts requiring replacement only with parts equivalent to those used in the original design.

• Do not alter powered industrial truck/forklift trucks so that the relative positions of the various parts are different than what they were when originally received from the manufacturer.

• Do not add additional counterweighting unless approved by the manufacturer.

• Trucks in need of repairs to the electrical system must have the battery disconnected prior to the repair work.

• If the temperature of any part of the powered industrial truck/forklift truck is found in excess of normal operating temperature, remove the powered industrial truck/forklift from service until the overheating is eliminated.

• Keep powered industrial truck/forklift trucks in a clean condition, free of lint and excess oil/grease.

• When antifreeze is used in the engine-cooling system, only use glycol-based material.

OSHA 1910.178 - Powered Industrial Trucks

FUELING PROCEDURESPropane

• Always wear the proper personal protective equipment when changing tanks. This includes protective eyewear, gloves and long sleeve shirts.

• Shut valve off to use up propane in the line before changing tanks.

• Shut off the ignition after engine stops.

• Do not change tanks near an open flame or heat source. (No smoking allowed in this area.)

• Propane is heavier than air, and it will settle to the floor if there is a leak.

• Check the condition of all valves and seals before connecting the new tank.

• Handle tanks carefully. Propane can cause a “freeze” burn if it comes in contact with your skin.

• Do not store tanks in areas where leaking propane gas might accumulate.

Gasoline or Diesel

• Always wear the proper personal protective equipment when fueling your powered industrial truck/forklift. This includes protective eyewear and gloves.

• Shut off the engine.

• Be sure to use the proper fuel.

• Avoid overfilling the tank.

• Clean up any spills following proper safety procedures for fuel spills.

• Check for any leaks.

• Replace the fuel cap.

Batteries

• Always wear the proper personal protective equipment when changing the battery. This includes protective eyewear and gloves

• Be aware of the nearest flushing station

• Shut off the engine

• Do not smoke or have an open flame in the battery changing area

• Do not locate battery charging stations within 36 inches of electrical panels

• Make sure the brake is set on the powered industrial truck/forklift before changing the battery.

• Make sure the battery is secure before lifting it

• Stand clear when moving the battery

• Make sure that the ventilation system is working properly before charging a battery

• Always add battery acid to water, never add water to battery acid

• If charging the battery on the powered industrial truck/forklift, uncover the battery compartment to prevent the build-up of heat and hydrogen gas

• Make sure that metal objects do not come in contact with the terminals on the battery

• Make sure the charger is off before connecting it to the battery

• Make sure the vent caps are not plugged

• Never plug the charger into the truck

• Provide a conveyor, overhead hoist, or equivalent material handling equipment to handle batteries

• Provide a carboy tilter or siphon for handling electrolyte

OSHA 1910.178 - Powered Industrial Trucks

PROGRAM AUDITThe Program Administrator will conduct a periodic review of this program to ensure it is operating effectively.

RECORDKEEPINGMaintain copies of daily vehicle inspection forms for a minimum of 6 months. Keep maintenance and service records for each vehicle for as long as the vehicle remains in service.

Maintain training records for each employee authorized to operate a powered industrial vehicle. The training records will include copies of the written test from the classroom training, the initial operator evaluation form, periodic operator evaluations, and documentation regarding retraining sessions if applicable.

Appendix A - Vehicle Inspection Checklist

Operator’s Daily Checklist—Electric Vehicles

Appendix B - Vehicle Inspection Checklist

Operator’s Daily Checklist—Gas, LPG and Diesel Vehicles

Appendix C - Powered Industrial Truck/Forklift Operator Evaluation

Operator’s Daily Checklist—Gas, LPG and Diesel Vehicles

Appendix C - Powered Industrial Truck/Forklift Operator Evaluation

Operator’s Daily Checklist—Gas, LPG and Diesel Vehicles (continued)

Appendix D - Order Picker Operator Evaluation

Order Picker Operator Evaluation Form

Appendix D - Order Picker Operator Evaluation

Order Picker Operator Evaluation Form (continued)

Appendix E - Reach Truck Operator Evaluation

Reach Truck Operator Evaluation Form

Appendix E - Reach Truck Operator Evaluation

Reach Truck Operator Evaluation Form (continued)