What equipment is covered?

• OSHA’s PIT standard applies to vehicles including forklifts, order pickers, powered pallet jacks, yard jockeys, and stand-up and narrow aisle lift trucks.
• The OSHA PIT standard does not cover scissor lifts, aerial lifts, or over-the-road haulage trucks and earth-moving equipment that has been modified to accept forks.

The Occupational Safety and Health Administration’s (OSHA) Powered Industrial Truck (PIT) standard applies to most types of material handling equipment that are powered for horizontal movement. This includes:

• Forklifts
• Order pickers
• Powered pallet jacks
• Yard jockeys
• Stand-up and narrow aisle lift trucks

What equipment is not covered?

OSHA’s PIT standard does not cover the following: scissor lifts, aerial lifts, or over-the-road haulage trucks and earth-moving equipment that has been modified to accept forks.

What are the different classes of PITs?

• Different classes of PITs are approved for different uses, but drivers must be trained and evaluated to the OSHA PIT standard to operate any of them.

There are many classes and types of Powered Industrial Trucks (PITs), from the common sit-down type to the narrow aisle stand-up type, and from order pickers to powered pallet jacks. They may be powered by electricity, liquefied petroleum gas (LPG), diesel fuel, or gasoline. Some classes are approved for use in certain hazardous conditions. PITs can be grouped into the following classifications:

• Class 1 — Electric motor, sit-down rider, counterbalanced trucks (solid or pneumatic tires).
• Class 2 — Electric motor, narrow aisle trucks (solid tires).
• Class 3 — Electric motor hand trucks or hand/rider trucks (solid tires).
• Class 4 — Internal combustion engine trucks (solid tires).
• Class 5 — Internal combustion engine trucks (pneumatic tires).
• Class 6 — Electric and internal combustion engine tractors (solid or pneumatic tires).
• Class 7 — Rough terrain trucks (pneumatic tires).

No matter the class, the Occupational Safety and Health Administration (OSHA) requires operators be trained and evaluated prior to operating the equipment in the workplace.

As a historical note, OSHA issued a Request for Information in the March 11, 2019, Federal Register, acknowledging that the PITs standard at 1910.178 lists 11 different designations of trucks— D, DS, DY, E, ES, EE, EX, G, GS, LP, and LPS. However, the notice stated that eight other type-designated units — CGH, CN, CNS, DX, G/CN, G/LP, GS/CNS, and GS/LPS — are not reflected in OSHA’s current standard. The agency explains that these eight type-designated units have different requirements for safe operation, maintenance, and handling due to their fuel source, but they are generally the same in design and function as the 11 truck types currently listed in the standard. OSHA is considering adding the eight truck types to modernize its standard, but a proposal is a long-term to-do item

What are the design requirements?

• OSHA requires that all PITs comply with the ANSI standard for safety.

The most basic provision in the Occupational Safety and Health Administration’s (OSHA) Powered Industrial Truck (PIT) standard is that equipment must be designed to meet certain safety standards. In doing this, OSHA requires that all new or acquired PIT equipment comply with the American National Standards Institute (ANSI) B56.1-1969.

The ANSI standard has undergone several revisions since 1969 — the most current being the 2020 edition — so most equipment purchased will likely be made to a newer version of ANSI B56.1 than what the OSHA standard references. As a historical note, on February 16, 2022, OSHA proposed to modernize the design and construction requirements for its PITs standard to add reference to the latest ANSI/ITSDF design and construction standards. These include ANSI/ITSDF B56.1-2020, B56.5-2019, and B56.6-2021. PIT manufacturers and users will want to watch for the issuance of a final rule.

Employers must pay particular attention with the rapid changes in technology for safety devices and attachments for forklifts and other PITs:

• Barcode scanners and Radio Frequency Identification (RFID) technology so employers can control who operates and inspects the equipment,
• GPS systems so employers can track equipment,
• Attachments to lift anything from a drum to carpet roll,
• QR codes that can link to training videos right from a smartphone, and
• Lights and alarms.

As long as equipment comes with these devices already installed by the manufacturer, there is usually no issue in regard to OSHA accepting the design, even though these devices may not have been available when the original OSHA standard was written.

What are the hazards?

• Different classes of PITs have different associated hazards, therefore requiring specialized approaches to accident prevention.
• Excessive speed, obscured vision, load instability, workplace conditions, and improper use are all common causes of PIT accidents in the workplace.

Powered Industrial Trucks (PITs) are used in almost all industries. They can be used to move, raise, lower, or remove large objects or a number of smaller objects on pallets or in boxes, crates, or other containers. Because PIT movement is controlled by the operator and is not restricted by the frame of the machine or other impediments, virtually unrestricted movement of the vehicle about the workplace is possible.

The hazards commonly associated with PITs vary for different vehicle types, makes, and models. Each type of truck presents different operating hazards. For example, a sit-down, counterbalanced high lift rider truck is more likely than a motorized hand truck to be involved in a falling load accident, because the sit-down rider trucks can lift a load much higher than a hand truck can.

Accident prevention

The methods or means to prevent an accident and to protect employees from injury vary for different types of trucks. For example, operators of sit-down rider trucks are often injured in tip-over accidents because of the natural tendency to jump downward and land on the floor or ground, where they can then be crushed by the vehicle’s overhead guard as the vehicle tips over. Therefore, operators of sit-down trucks need to be trained to remain in the operator’s position in a tip-over accident and to lean away from the direction of fall to minimize the potential for injury.

On the other hand, when a stand-up rider truck tips over, the truck operator can exit the vehicle by simply stepping backward, perpendicular to the direction of the vehicle’s fall, to avoid being crushed. In this situation, the operator usually should attempt to jump clear of the vehicle and should be trained accordingly.

Safe operation and workplaces

Driving a PIT at excessive speed can result in loss of control, causing the vehicle to skid, tip over, or fall off a loading dock or other elevated walking-working surface. This accident can be made more dangerous if the load being carried partially obscures the operator’s vision. A vehicle that is out of control or being operated by a driver whose vision is obscured can strike an employee, run into a column or other part of the building, or strike material, causing it to topple and injure employees in the area. Effective driver training teaches operators to minimize these hazards.

Other characteristics of a PIT that affect safe truck operation are the truck’s tendency to become unstable, its ability to carry loads high off the ground, and its characteristic mode of steering with the rear wheels while being powered by the front wheels. Moving loads upward, downward, forward, and backward causes a shift of the center of gravity of the vehicle and can adversely affect its stability. When a load is raised or moved away from the vehicle, the vehicle’s longitudinal stability is decreased. When the load is lowered or moved closer to the vehicle, its longitudinal stability is increased.

The workplaces where PITs are being used can also present a variety of different hazards. The safety of industrial truck operations can be decreased by workplace conditions such as rough, uneven, or sloped surfaces; unusual loads; hazardous areas; narrow aisles, blind spots, or intersections; and pedestrian traffic or employees working close to the path of travel. Finally, there are hazardous work practices that relate to all trucks, including operating at excessive speed, operating too close behind another PIT, poor loading practices, and carrying unauthorized passengers. In addition, poor truck maintenance can contribute to accidents.

Many accidents have occurred because of unsafe truck operation. For example, employees have fallen from trucks while using them to change light bulbs on overhead fixtures or riding on the forks to manually retrieve items from high racks. Many accidents have occurred when an operator has attempted to drive with an obstructed view in the direction of travel and has run into another employee. Improper truck maintenance has caused death from over exposure to carbon monoxide, loss of brakes, or rupture of hydraulic lines. Also, PITs that damage the legs of a storage rack may expose employees to struck-by hazards from falling materials stored on the rack.

Caution about under-ride hazards

A stand-up forklift operator was crushed and killed when the bottom half of the forklift passed beneath a beam of a storage rack. The Occupational Safety and Health Administration (OSHA) cited the employer under section 5(a)(1) of the Occupational Safety and Health Act for not furnishing a workplace free of recognized serious hazards, such as the under-ride hazard. The Occupational Safety and Health Review Commission later confirmed that employer training and extra-wide aisles were “inadequate” precautions in the case. Instead, the commission said OSHA’s suggested abatement measures were physically and economically feasible and would materially reduce the hazard. Those measures included adjusting shelf heights, installing rack barriers, or installing rear post guards on the forklifts.

What are key definitions?

• There are a few key terms to understand in order to ensure safe PIT operation in a workplace.

Center of gravity: The point on an object at which all of the object’s weight is concentrated. For symmetrical loads, the center of gravity is at the middle of the load.

Counterweight: The weight that is built into the truck’s basic structure and used to offset the load’s weight and maximize the vehicle’s resistance to tipping over.

Grade: The slope of a surface, which is usually measured as the number of feet of rise or fall over a 100-foot horizontal distance (the slope is expressed as a percent).

Load center: The horizontal distance from the load’s edge (or the fork or other attachment’s vertical face) to the line of action through the load’s center of gravity.

Powered industrial truck (PIT): Fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines, excluding compressed air or nonflammable compressed gas-operated industrial trucks, farm vehicles, and vehicles intended primarily for earth moving or over-the-road hauling.

Stability triangle: The three-point suspension system that runs along an imaginary line between a forklift’s two front tires and the center of the rear axle. Even though the vehicle has four wheels, it is only supported at these three points.

Motorized hand truck: The Occupational Safety and Health Administration’s (OSHA) term for a powered pallet jack.

Pallet jack: A type of PIT used to move materials from one place to another. They do not typically raise the material very high.

Walkie: A common industry term for powered pallet jack that can only be operated by a walking operator.

Walkie-rider: A type of pallet jack that can be operated by a walking operator on the ground, or by a riding operator who stands on a built-in platform.

What are the training requirements?

• OSHA does not have specific requirements or certifications for trainers of PIT operators, other than that they must possess the “knowledge, training, and experience” to train and evaluate operators.
• PIT operators must have their performance evaluated initially and every three years and participate in refresher training when needed.

Failure to train and evaluate a Powered Industrial Truck (PIT) operator is a top serious OSHA violation for the PITs standard, so that means Occupational Safety and Health Administration (OSHA) officers will likely be checking to see that proper training has been completed in any facility with PIT operations, and failure to train PIT operators can lead to hefty OSHA penalties.

OSHA has specific requirements for PIT operator training. These requirements include who can train operators, the frequency at which they should be trained, the content of the trainings, and more specific requirements based on the type of truck and workplace.

Who can train?

OSHA requires that trainers have the “knowledge, training, and experience” to train operators and evaluate their competence. The OSHA standard does not further define this requirement or set any specific certifications.

However, for PIT operators that are temporary employees, OSHA’s Temporary Worker Initiative (TWI) Bulletin No. 7 explains that the staffing agency is responsible for generic PIT training, and the host employer provides the necessary site-specific PIT training and evaluation. That’s because the host employer is most familiar with the equipment being used and controls the conditions of the worksite.

Frequency

While forklift training is not required annually, OSHA does require an evaluation of each PIT operator’s performance at least once every three years.

In addition, refresher training must be provided when:

1. The operator has been observed to operate the vehicle in an unsafe manner.
2. The operator has been involved in an accident or a near-miss incident.
3. The operator has received an evaluation that reveals that they are not operating the truck safely.
4. The operator is assigned to drive a different type of truck.
5. A condition in the workplace changes in a manner that could affect safe operation of the truck.

Content

PIT operators must receive a combination of the following types of training:

• Formal instruction, such as: lecture, discussion, interactive computer learning, video, and/or written material.
• Practical training, including: demonstrations performed by the trainer, and practical exercises performed by the trainee.
• Evaluation of the operator’s performance in the workplace.

What are the requirements to operate in hazardous atmospheres?

• Depending on hazards present, certain Powered Industrial Truck (PIT) types are better suited for different workplaces.

Where chemicals or other hazardous substances are or can be present, special precautions must be taken to select the correct type of PIT.

To make the correct selection, the employer must know the:

• Type of location (known as Class),
• Specific chemical or substance,
• Likelihood for the hazard to exist (Division), and
• Type Designation for each PIT.

Classified locations

The table below, used with permission of the Washington Department of Labor and Industries, shows the criteria to pick the safest forklift for certain workplaces.

1. The first column of the table shows the hazard class of the material.
2. The rows contain chemicals or substances that might be handled at a workplace.
3. The second and third columns are the divisions that represent the exposure condition.
4. The hazard designations listed in the second or third column are interpreted in the Explosion/Combustion Hazards table below.

Explosion/Combustion hazards

All forklifts have a hazard designation assigned to them that tells whether they are suitable for use in certain kinds of hazardous atmospheres. The designation can be found on the forklift’s load capacity plate. The table below explains the designations.

What are capacity and stability requirements?

• PIT operators must participate in stability training.

Perhaps the most critical operational element for Powered Industrial Trucks (PITs) is capacity and stability. In fact, it’s the basic reason most PITs exist. But it can be a hard concept to grasp and explain to workers.

Most PITs work on essentially the same principle as a teeter-totter — the weight of the load on the forks must be counterbalanced by the weight of the truck body. The load weight that each lift can handle can be found on the nameplate, also known as a data plate, capacity plate, or ID plate. The nameplate will state the capacity of the lift — in other words, the manufacturer’s guideline for how much weight can be safely lifted.

The capacity data on the nameplate is critical information, but it was calculated using a load with a specific load center, commonly 24 inches. So, unless every load an operator lifts has a load center of 24 inches — or whatever load center the truck was rated at — and is placed perfectly on the forks, employers have to remember that the actual capacity will be reduced. The same thing goes for attachments — which also typically reduce capacity.

Stability training

Trainers need to have a thorough understanding of load composition and impart it to operators. Trainers must be thoroughly familiar with concepts such as:

• Center of gravity — The point on an object at which all of the object’s weight is concentrated. For symmetrical loads, the center of gravity is at the middle of the load.
• Counterweight — The weight that is built into the truck’s basic structure and used to offset the load’s weight and maximize the vehicle’s resistance to tipping over.
• Fulcrum — The truck’s axis of rotation when it tips over.
• Grade — The slope of a surface, which is usually measured as the number of feet of rise or fall over a 100-foot horizontal distance (the slope is expressed as a percent).
• Lateral stability — A truck’s resistance to overturning sideways.
• Line of action — An imaginary vertical line through an object’s center of gravity.
• Load center — The horizontal distance from the load’s edge (or the fork or other attachment’s vertical face) to the line of action through the load’s center of gravity.
• Longitudinal stability — The truck’s resistance to overturning forward or rearward.
• Moment — The product of the object’s weight times the distance from a fixed point (usually the fulcrum). In the case of a PIT, the distance is measured from the point at which the truck will tip over to the object’s line of action. The distance is always measured perpendicular to the line of action.
• Track — The distance between the wheels on the same axle of the truck.
• Wheelbase — The distance between the centerline of the vehicle’s front and rear wheels.

How are PITs inspected?

• OSHA has specific standards for the frequency of PIT inspections.

Frequency

The Occupational Safety and Health Administration (OSHA) requires that forklift vehicles be inspected at least daily, or after each shift when used around the clock.

What are safe operation requirements?

• OSHA has specific tips and rules to ensure the safe operation of PITs.

Safe procedures

The Occupational Safety and Health Administration’s (OSHA) Powered Industrial Truck (PIT) standard does provide a few “rules of the road” that operators should adhere to. The key to a successful safety program is setting proper rules, training operators on those rules, and then following up consistently when there are deviations.

The basic rule for traveling is that operators maintain control of the PIT at all times. Other rules include:

• Operators must only operate a forklift while in the seat or operator’s station. The operator should never start it or operate the controls while standing beside the forklift.
• Operators should never allow passengers unless the PIT was designed for a passenger.
• Operators should not put any part of their body between the uprights of the mast, or when traveling, outside of the forklift frame.
• Operators should always look in the direction of travel and keep a clear view of the travel path, and travel in reverse if the load blocks their view.
• Operators should keep a distance of at least three forklift lengths between themselves and any forklift traveling in front of them.
• Operators should not pass a forklift traveling in the same direction if it is at a blind spot, intersection, or other dangerous location.
• Operators should never drive a forklift up to anyone in front of a bench or other fixed object.
• Operators should never allow anyone to walk or stand under the elevated forks, even if the forks are not carrying a load.
• Operators should check that there is adequate clearance under beams, lights, sprinklers, and pipes for the forklift and load to pass.
• Operators should never engage in stunt driving or horseplay.

Load handling

Many incidents can happen during load placement or retrieval. To avoid this, employers should ensure that operators are:

• Making sure the load is stable before picking it up and securing it as necessary;
• Checking that the load fits within the capacity of the PIT, factoring in the highest elevation and extension to be used;
• Placing the forks squarely into the load, with forks spread to keep the load balanced;
• Driving the forks all the way under the load;
• Tilting the mast to stabilize the load and lift;
• Checking the destination or drop off point, refraining from placing heavy loads on light loads, observing stacking heights or limitations if listed on the carton/box, knowing the racking capacities they’ll be using, and checking that racks are in good condition;
• Using a spotter when needed;
• Using access control when needed, either cones or spotter; and
• Placing the load at the destination by squaring up in front of the rack, stack or location, tilting the mast to level, lowering the forks, and backing away.

How do employees operate safely around pedestrians?

• OSHA has specific requirements for workplace environments where PITs are being operated to ensure pedestrian safety.

The Occupational Safety and Health Administration (OSHA) requires that permanent aisles and passageways be free from obstructions and appropriately marked where mechanical handling equipment is used. OSHA recommends that employers consider separating pedestrians from lift trucks by providing:

• Pedestrian walkways;
• Permanent railings or other protective barriers;
• If pedestrians must use equipment aisles, adequate walking space at least on one side;
• If barriers cannot be used, pedestrian walkway striping on the floor;
• Convex mirrors at blind aisle intersections; and/or
• Traffic control signs and posted speed limits.

Operators and pedestrians should be trained on the plant’s procedures and hazards associated with Powered Industrial Truck (PIT) operation in pedestrian areas.

It is noteworthy that OSHA proposed a nearly $13,000 penalty for a serious violation of Section 5(a)(1) of the Occupational Safety and Health Act when a distribution center allegedly exposed employees to struck-by hazards from PITs and over-the-road trucks in the yard area at night. The agency explains that the company could abate the hazards by providing and requiring the use of high visibility reflective vests for workers who walk or work in the yard area.

What are requirements for parking?

• Operators must take specific actions before leaving a PIT unattended in a workplace.

A Powered Industrial Truck (PIT) is considered “unattended” when the operator is 25 feet or more away from the vehicle (even if it remains in their view), or whenever the operator leaves the vehicle, and it is not in their view.

When a PIT is left unattended, the:

• Load engaging means must be fully lowered,
• Controls neutralized,
• Power shut off, and
• Brakes set.

Note: Wheels must be blocked if the truck is parked on an incline.

When the operator of an industrial truck is dismounted and within 25 feet of the truck still in their view, the:

• Load engaging means must be fully lowered,
• Controls neutralized, and
• Brakes set.

Put another way, when the operator is dismounted and within 25 feet of the PIT still in the operator’s view, as long as the operator takes the three actions, the power may be left on.

OSHA was asked to define “in his [or her] view,” wondering if this includes when the operator is not looking at the vehicle for short periods of time. The agency replied in a September 11, 2018, letter of interpretation, “The standard does not define the term ‘in his [or her] view.’ ... [A] vehicle would normally remain in view of an operator during momentary or brief periods of time that an operator may glance away from the vehicle, provided that there are no other obstructions to the view.”

How do PITs operate on ramps/inclines?

• Operators must follow procedures to ensure safety when operating PITs on ramps and inclines.

Many injuries occur when forklift operators lose control while driving on ramps. For example, an operator was backing a forklift out of a warehouse and came too close to the side of a ramp. The forklift went over the edge of the ramp, tipped over, and crushed the operator.

Operators should be aware of procedures to follow when traveling on ramps and other inclines with a load. These include:

• When traveling with a load, the load should point up the incline, regardless of direction of travel. This keeps weight on the wheels to allow for steering, and helps secure the load.
• When traveling without a load, the forks should point downgrade, regardless of direction of travel.

When walking with a pallet jack with or without a load, generally the forks should be pointed downgrade, regardless of direction of travel.

Where are the requirements to enter truck trailers?

• Special precautions must be taken when entering truck trailers with a PIT.

One of the most dangerous operations involving powered industrial trucks (PITs) is the loading or unloading of trucks, trailers, and railroad cars. Not only may the vehicle being entered be unstable, but the means of going from the warehouse to the vehicle by way of a dockplate can also be dangerous. While entering and leaving truck trailers or railroad cars, operators must be aware of the following:

• Falling off the edge of a loading dock.
• Trucks or railroad cars moving during loading and unloading.
• Slipping or inadequate dockboards.

What are requirements for fueling?

• When it comes to batteries and fueling, OSHA has specific safety requirements for PIT operators.

Battery charging

The Occupational Safety and Health Administration (OSHA) requires employers to charge batteries only in a properly equipped location. A properly equipped battery charging area will have:

• No smoking.
• Warning signs posted.
• Adequate fire protection.
• Ample and readily available water supply for flushing and neutralizing spilled electrolyte.
• An eyewash able to provide a 15-minute flow, and for large installations, a drench shower and an eyewash.
  Note: OSHA has said that where batteries are simply being plugged in for charging — there is no maintenance performed, no removal of batteries from the trucks, and no electrolyte is present in the area — there usually isn’t a need for an eyewash/shower.
• A phone or other means of communication in the event of an emergency.
• Adequate ventilation to avoid the buildup of hydrogen gas during battery charging.
• Soda ash or other neutralization materials in the immediate area.
• A dry chemical, CO2, or foam fire extinguisher.
• Means to protect charging apparatus from damage from trucks.

Only trained personnel should charge and change batteries in electric forklifts. In addition to training in battery changing and charging procedures, these employees should be trained on emergency procedures in the event of an acid splash, including how to use eyewash and shower facilities.

OSHA directive STD 01-11-004 offers further clarification. It says that “battery charging” areas where power industrial truck batteries are charged only — meaning no maintenance is performed, batteries are not removed from the trucks, and no electrolyte is present in the area — are not subject to the requirement of paragraph (g)(2) of 1910.178. However, the charging areas shall be in compliance with paragraphs (g)(1) and (g)(8) to (g)(12) of the regulation, and personal protective equipment (PPE) shall be used when and where required.

Best practices and requirements

In addition to having a properly equipped charging area, it is important employees follow safety procedures when charging batteries. OSHA has requirements covering some portions of the charging operation. Trained personnel should:

• Follow the recharger manufacturer’s recommendations for attaching and removing cables and for proper operation of the equipment.
• Properly position trucks and apply brakes before attempting to change or charge batteries.
• Use a lifting beam or equivalent material handling equipment when lifting the battery. Employees should not use a chain with two hooks. This may cause distortion and internal damage.
• Charge batteries in the designated battery charging area.
• Pour acid into water when charging batteries. Employees should never pour water into acid.
• Take care to assure that vent caps are functioning. The employee must ensure the battery (or compartment) cover(s) are open to dissipate heat.
• Prohibit smoking in the charging area.
• Take precautions to prevent open flames, sparks, or electric arcs in battery charging areas.
• Remove all metallic jewelry before recharging. Employees should keep tools and other metallic objects away from the top of uncovered batteries.
• Wear PPE (e.g., face shield, safety goggles, neoprene or rubber gloves and apron).
• Check the electrolyte level before recharging. Employees should record the specific gravity with the hydrometer in the service log and check the pilot cell.
• Check the water level. Employees should not add water prior to recharging. This should be recorded in the service log.
• Check the voltage. If the battery has sealed vents, employees should not recharge with a current greater than 25 amperes.
• Unplug and turn off the charger before connecting or disconnecting the clamp connections.
• Attach the positive clamp (+, usually colored red) to the positive terminal first and then the negative clamp (-, usually colored black) to the negative terminal, keeping the proper polarity.
• Turn off the charger if the battery becomes hot or the electrolyte fluid comes out of the vents. Employees should restart charging at a lower charging rate.
• Check water level after charging. Employees should add distilled water or de-ionized water if water level is below level indicator and record in service log.
• Return battery to forklift with lifting beam and secure in place after charging.
• Check the indicator on the hour meter to see that the battery is fully charged.

What requirements apply to modifications/attachments?

• Any PIT modifications or attachments must be approved by the manufacturer and comply with OSHA requirements.

When it comes to making modifications to forklifts or other Powered Industrial Trucks (PITs), the Occupational Safety and Health Administration (OSHA) is stringent. OSHA requires that employers obtain the manufacturer’s prior written approval for modifications or additions that “affect capacity and safe operation.” OSHA has interpreted this provision broadly to include most lifting attachments, as well as manbaskets.

When these changes are allowed, capacity, operation, and maintenance instruction plates, tags, or decals must be changed accordingly.

Front-end attachments

If the truck is equipped with front-end attachments other than factory installed attachments, employers must request 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.

Other provisions

OSHA also has a couple of other “hidden” provisions that pertain to altering PITs. (“Hidden” in that they are in a separate section of the regulation than the modification/attachment section.)

OSHA requires that all parts be replaced only by parts equivalent as to safety with those used in the original design.

OSHA also requires that PITs are not altered so that the “relative positions” of the parts are different from what they were when originally received from the manufacturer. They must not be altered either by the addition of extra parts not provided by the manufacturer or by the elimination of any parts.

When in doubt, ask

When an employer or employee has questions about adding or replacing parts, it’s best to check with the equipment manufacturer or OSHA local area office, to be on the safe side. There are many variables that can come into play, and that may not be obvious at first glance. For example, the addition of an after-market hours meter may seem (and may well be) perfectly harmless, but if the truck has been rated to operate in certain explosive/hazardous locations, the installation could potentially negate that rating if the meter isn’t up to the same standards.

What requirements apply to safety devices, lights?

• Employers must ensure the use of safety devices such as seat belts and horns on PITs.

Powered Industrial Trucks (PITs) can incorporate many warning and safety devices to help protect operators, pedestrians, and other PIT operators. Some are required, some recommended, and some required only in certain instances.

The Occupational Safety and Health Administration (OSHA) specifically requires an operator-controlled horn for PITs.

OSHA also requires directional lighting when general lighting is less than two lumens per square foot. For example, the general lighting in an inspected warehouse where PITs were used was less than 1 lumen per square foot, and the trucks did not have directional lighting. OSHA cited the company for a willful violation, which brought a $62,537 penalty.

As far as other beepers/lights (such as backup warnings and strobe lights), there is no specific requirement, but OSHA has said that if these warnings are needed based on the specific operating conditions, then the Agency could cite employers under the General Duty Clause of the Occupational Safety and Health Act.

What about seatbelts?

OSHA’s current enforcement policy is that employers must require operators of equipment that are equipped with operator restraint devices, including seat belts, to use the devices.

In addition, OSHA may also cite employers who do not take advantage of a manufacturer operator restraint system or seat belt retrofit program. Two enforcement cases illustrate this approach:

• Case 1 — An OSHA inspector witnessed an employee operating a forklift without wearing the required seatbelt that was provided. The employee was moving product around the refrigerated warehouse. The inspector cited the warehouse under the General Duty Clause (Section 5(a)(1) of the OSH Act). The citation explained that the employer did not ensure that employees operating PITs use seatbelts, exposing employees to the hazard of falling out of and being struck by the PIT. The citation suggested that one feasible and acceptable abatement method to correct this hazard is to require all operators to read and follow the manufacturer’s operator manual and abide by the safety rules and practices, in accordance with ANSI B56.1, Safety Standard for Low Lift and High Lift Trucks.

• Case 2 — In another case, a forklift collided with a concrete column, and the operator died after being thrown from the forklift. California OSHA says the worker was not wearing a seatbelt. However, the agency also discovered that two safety devices were disabled. Proposed penalties climbed up over $205,000. The citations included four serious violations for the employer’s alleged: failure to ensure that forklift operators use seatbelts; failure to properly maintain and inspect forklifts; failure to ensure operators were effectively trained; and improper alterations of forklift safety features. The company was also issued a citation for a willful violation for allegedly failing to ensure workers perform a forklift safety check at the beginning of each shift and report unsafe conditions, a violation the company was also cited for in a previous year.

Specialized equipment

• OSHA’s PIT standard includes powered pallet jacks, requiring proper operator training and daily inspections.

Truck-specific

• OSHA requires employees to be trained on the specific type of PIT they will be operating.

The Occupational Safety and Health Administration (OSHA) regulation outlines several Powered Industrial Truck (PIT)-related topics:

Workplace-specific

• The Occupational Safety and Health Administration (OSHA) regulations require workplace-specific Powered Industrial Truck (PIT) training.

• Surface conditions where the vehicle will be operated;
• Ramps and other sloped surfaces that could affect the vehicle’s stability;
• Composition of loads to be carried and load stability;
• Load manipulation, stacking, and unstacking;
• Pedestrian traffic in areas where the vehicle will be operated;
• Narrow aisles and other restricted areas where the vehicle will be operated;
• Hazardous (classified) locations where the vehicle will be operated;
• Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust; and
• Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation.

Evaluation

Evaluation of each PIT operator’s performance is required at least once every three years.

Certification

OSHA has no requirement that a forklift operator have a valid driver’s license but does require that every forklift operator be trained and certified to operate the PIT in the workplace. The employer must have a record documenting that the driver has successfully completed the training.

Stability

• The three-point support system on counterbalanced PITs forms a stability triangle.
• To avoid tipping, a PIT must achieve longitudinal, lateral, and dynamic stability.

Stability triangle

Almost all counterbalanced PITs have a three-point suspension system, meaning the vehicle is supported at three points. This is true even if the vehicle has four wheels. The truck’s steer axle is attached to the truck by a pivot pin in the axle’s center. When the points are connected by imaginary lines, this three-point support forms a triangle called the stability triangle.

Longitudinal stability

The axis of rotation when a truck tips forward is the front wheels’ points of contact with the pavement. When PITs tip forward, the truck will rotate about this line. When a truck is stable, the vehicle moment must exceed the load-moment. As long as the vehicle-moment is equal to or exceeds the load-moment, the vehicle will not tip over. On the other hand, if the load-moment slightly exceeds the vehicle-moment, the truck will begin to tip forward, thereby causing the rear to lose contact with the floor or ground and result in loss of steering control. If the load-moment greatly exceeds the vehicle-moment, the truck will tip forward.

To determine the maximum safe load-moment, the truck manufacturer normally rates the truck at a maximum load at a given distance from the front face of the forks. The specified distance from the front face of the forks to the line of action of the load is the load center.

Because larger trucks normally handle loads that are physically larger, these vehicles have greater load centers. Trucks with a capacity of 30,000 pounds or less are normally rated at a given load weight at a 24-inch load center. Trucks with a capacity greater than 30,000 pounds are normally rated at a given load weight at a 36- or 48-inch load center. To safely operate the vehicle, the operator should always check the data plate to determine the maximum allowable weight at the rated load center.

Although the true load-moment distance is measured from the front wheels, this distance is greater than the distance from the front face of the forks. Calculating the maximum allowable load-moment using the load-center distance always provides a lower load moment than the truck was designed to handle.

When handling unusual loads, such as those that are larger than 48 inches long (the center of gravity is greater than 24 inches) or that have an offset center of gravity, etc., a maximum allowable load moment should be calculated and used to determine whether a load can be safely handled. For example, if an operator is operating a 3,000-pound capacity truck (with a 24-inch load center), the maximum allowable load-moment is 72,000 inch-pounds (3,000 times 24). If a load is 60 inches long (30-inch load center), then the maximum that this load can weigh is 2,400 pounds (72,000 divided by 30).

Lateral stability

The vehicle’s lateral stability is determined by the line of action’s position relative to the stability triangle. When the vehicle is not loaded, the truck’s center of gravity location is the only factor to be considered in determining the truck’s stability. As long as the line of action of the combined vehicle and load’s center of gravity falls within the stability triangle, the truck is stable and will not tip over. However, if the line of action falls outside the stability triangle, the truck is not stable and may tip over.

Factors that affect the vehicle’s lateral stability include the load’s placement on the truck, the height of the load above the surface on which the vehicle is operating, and the vehicle’s degree of lean.

Dynamic stability

The stability of a PIT is further complicated by dynamic forces that result when the vehicle and load are put into motion. The weight’s transfer and the resulting shift in the center of gravity due to the dynamic forces created when the machine is moving, braking, cornering, lifting, tilting, and lowering loads, etc., are important stability considerations.

When determining whether a load can be safely handled, the operator should exercise extra caution with loads that cause the vehicle to approach its maximum design characteristics. For example, if an operator must handle a maximum load, the load should be carried at the lowest position possible, the truck should be accelerated slowly and evenly, and the forks should be tilted forward cautiously. However, no precise rules can be formulated to cover all of these eventualities.

Daily inspections – External

• A PIT’s tires, forks, mast and carriage, body, cab, and (for certain types) platform must be inspected daily to ensure proper operation and safety in the workplace.

The daily inspection requirements below broadly apply to several kinds of Powered Industrial Trucks (PITs): electric forklifts, gas and diesel forklifts, liquefied petroleum gas (LPG) forklifts, order pickers, powered pallet jacks, reach trucks, and stand-up tow tractors. They must be inspected for these requirements daily, with additional specific requirements for every type of PIT.

Tires

On electric forklifts, gas and diesel forklifts, LPG forklifts, powered pallet jacks, reach trucks, stand-up tow tractors, and pallet jacks, the tires must be in good repair (e.g., no cuts, separation from the rim, or excessive wear) and properly inflated. There must be lug nuts present on each tire, and the lug nuts must each be tightly secure.

Forks

On electric forklifts, gas and diesel forklifts, LPG forklifts, order pickers, powered pallet jacks, reach trucks, and pallet jacks, the forks must be properly aligned and in good repair (e.g., no cracks, bends, or excessive wear). Where present, the top clip retaining pin for each fork must be tightly secure and in good repair (e.g., no cracks). Load back rests must be securely attached and in good repair (e.g., no cracks or bends).

On reach trucks, the telescoping forks must be in good repair (e.g., no cracks, bends, or excessive wear).

Mast and carriage

On electric forklifts, gas and diesel forklifts, LPG forklifts, order pickers, and reach trucks, the mast assembly must be in good repair (e.g., no cracks or dents, missing stops, or broken welds). The hydraulic cylinders must be in good repair (e.g., no cracks or leaks). The lift chains and rollers must be in good repair (e.g., no cracks, kinks, or rust) and properly lubricated. Additionally, the tension of the lift chains must be correct.

On an order picker, the hoist lines, cables, lift chains, and rollers must be in good repair (e.g., no cracks, kinks, or rust).

Body

The body of the PIT must be in good repair (e.g., no cracks or dents) and clean (e.g., no grease or lint). The covers over the battery and other hazardous parts must be in place and secure. The overhead guard must be securely attached and in good repair (e.g., no cracks, bends, broken welds, or missing bolts). The nameplate must be present and legible. The safety decals or warning labels must also be legible. Any wiring, belts, lights, headlights, taillights, reflectors, warning lights, hoses, chains, and cables must be in good repair (e.g., no cracks, bends, frays, breaks, leaks, or kinks). Any lights or headlights must be aimed correctly. The control levers must be properly labeled.

On a powered pallet jack, the operator must ensure the hand guard is in place.

Cab

The cab should be clean, with the seatbelt working properly and in good repair (e.g., no frays or excessive wear). The seat itself must also be in good repair and adjusted properly. Control levers must be properly labeled. The mirrors must be in good repair (e.g., no cracks or breaks), clean, and adjusted properly.

Platform

Operators of order pickers, powered pallet jacks, and stand-up tow tractors must also inspect the PIT’s platform. The order picker’s work platform must be clean and in good repair (e.g., no cracks or holes). The guardrails or other limiting devices on the order picker must be in good repair (e.g., no cracks or bends) and must close properly and lock securely. The powered pallet jack and stand-up tow tractor riding platforms must be clean and in good repair (e.g., no cracks or holes).

Daily inspections — Operational

• A PIT’s fluids, power sources, attachments, systems and controls, must be inspected and maintained to ensure proper operation and safety in the workplace.

Fluids

Where applicable, such as sit-down forklifts, hydraulic and brake fluid levels must be adequate.

Gas or diesel forklifts should have sufficient fuel for operation and adequate engine oil and radiator coolant levels.

Where applicable, operators should ensure the engine oil level, radiator coolant level, and transmission fluid level are adequate.

Battery

A PIT’s battery must be charged and in good repair (e.g., no corrosion or missing cable insulation), with its connections tight and in good repair (e.g., no cracks or excessive wear) as well. The cell caps in the battery cover must be in place and the electrolyte level must be adequate.

Battery gates (pallet jacks) and compartments should be secured.

Attachments

The nameplate on the PIT should account for any attachment being used, with the attachment in good repair (e.g., no cracks or bends).

Systems and controls

PIT inspectors (which can be the operator) must check that several components of the system and controls are working. They must check if the motor is running smoothly. They must also check that the accelerator is working and functioning smoothly, and that the steering is smooth and responsive (e.g., free of excessive play).

The employee must ensure the horn, whistle, gong, or other warning device sounds. The brake must be working and functioning smoothly (e.g., no grabbing), along with the parking brake (e.g., holds the forklift on the incline). The drive control and tilt control must work in forward and reverse and function smoothly (e.g., no excess drift for the tilt control). The lift controls must raise and lower the forks properly and function smoothly (e.g., no excess drift), and the attachment control must work and function smoothly (e.g., no hesitation). Additionally, the turn signal, backup alarm, lights, battery discharge indicator, and hour meter should also be working.

On electric forklifts, order pickers, powered pallet jacks, reach trucks, stand-up tow tractors, and pallet jacks, employees should ensure the battery discharge indicator is working.

Gas or diesel forklift and LPG forklift operators must ensure the engine runs smoothly, and that the fuel gauge, ammeter indicator lamp, oil pressure indicator lamp, and water temperature gauge work.

Propane tank

On an LPG forklift, the operator must ensure the propane tank restraint brackets are in good repair (e.g., no cracks, bends, or rust) and that the tank is properly mounted on the locator pin. The tank must fit within the profile of the truck and be in good repair (e.g., no cracks, dents, or rust). The hoses and connectors must be in good repair (e.g., no cracks or kinks) and securely attached. Additionally, the pressure relief valve must be pointing up.

Removal from service

• Any safety issues identified during a daily inspection must be fixed before a Powered Industrial Truck (PIT) is operated again.

Once an inspection has been conducted, the Occupational Safety and Health Administration (OSHA) expects employers to fix safety issues before allowing operation. But what constitutes something severe enough to require the equipment be taken out of service?

In OSHA’s standards, there are a few very specific conditions that warrant immediate removal of equipment from service. These include:

• Hazardous sparks from the exhaust,
• Excess operating temperatures, and
• Leaky fuel systems.

In addition, there is also a general provision to remove “unsafe” equipment. OSHA has said they will take a variety of factors into consideration when making the determination as to whether a truck is unsafe. But, at the least, any item that could present harm or risk would need to be taken out of service.

Items that could constitute unsafe conditions include:

• Improperly functioning gauges,
• Broken welds,
• Missing bolts,
• Damage to the overhead guard, and
• Tires missing large pieces of rubber.

Pallet jack

• OSHA requires powered pallet jack operators to inspect their vehicle daily.

Pallet jacks have their own set of inspection requirements. Pallet jack operators must inspect the:

• Forks
• Raise/lower controls
• Forward/reverse controls
• Tires
• Frame
• Control arm
• Backrest
• Belly button switch
• Hand guard
• Brakes
• Grab bar (if applicable)
• Horn
• Data plate
• Warning labels
• Battery (condition/cables)
• Battery compartment/retainer
• On/off/disconnect

General

• There are specific ANSI standards for the general use and maintenance of PITs and the workplaces they operate in.

Operation

All Powered Industrial Trucks (PITs) must be designed and constructed in compliance with the American National Standards Institute (ANSI) standard B56.1-1969. (1910.178(a)(2)) Employers must ensure that only approved trucks are used in areas where flammable gases or vapors, combustible dust, or ignitable fibers are present in the atmosphere. Trucks with internal combustion engines that operate in buildings or enclosed areas must be checked to ensure they do not cause harmful concentrations of dangerous gases or fumes.

Any trucks not in safe operating condition are to be promptly removed from service. (1910.178(q)(1)) Repairs to fuel and ignition systems must be conducted only in areas specifically designated for them. (1910.178(q)(3)) Trucks are to be inspected daily, or after each shift if used around the clock, and before being placed in service. (1910.178(q)(7)) Directional lighting must be provided on each truck that operates in an area with less than two foot-candles per square foot of general lighting. (1910.178(h)(2)) Any trucks used by a company must be correctly designated for that type of operation (based on atmosphere, hazards of materials handled, etc.). (1910.178(c)(2))

Material handling

When assessing how a PIT will handle material, employers and operators must ensure there is sufficient clearance for equipment through aisles and doorways. (1910.176(a)) There must also be clearance signs to warn of clearance limits, and permanent aisles and passageways must be appropriately marked. (1910.176(e), 1910.176(a)) Bags, containers, bundles, etc. need to be stacked, blocked, interlocked, and limited in height so they are stable and secure. (1910.176(b))

Operators must use dock boards (bridge plates) when loading or unloading operations are taking place between vehicles and docks, and trucks and trailers should be secured from movement. (1910.178(m)(7))

Battery charging

Battery charging installations (located in areas designated for that purpose) and the batteries themselves must be charged in a properly vented room. (1910.178(g)(1), 1910.178(g)(2)) The local ventilation must be sufficient to disperse fumes. (1910.178(g)(2)). Facilities must be provided for flushing and neutralizing spilled electrolyte, fire protection, and protecting charging apparatus from damage by trucks. (1910.178(g)(2))

A conveyor, overhead hoist, or equivalent material handling equipment must be provided for handling batteries. (1910.178(g)(4)) Any reinstalled batteries must be properly positioned and secured in the truck. (1910.178(g)(5)) A carboy tilter or siphon must be provided for handling electrolyte. (1910.178(g)(6))

When charging batteries, employees must make certain not to pour water into acid, and that trucks are properly positioned with brakes applied first. (1910.178(g)(7), 1910.178(g)(8)) They must also ensure that the vent caps are functioning. (1910.178(g)(9)) Smoking must be prohibited in battery charging areas, and precautions taken to prevent open flames, sparks, or electric arcs in the charging area, such as keeping tools and other metallic objects away from the top of any uncovered batteries. (1910.178(g)(10)-(12))

Fueling

Fueling an internal combustion engine with a flammable liquid while the engine is running must be prohibited. (1910.178(p)(2)) Employees should ensure fueling operations are done in such a manner that the likelihood of spillage will be minimal. (1910.178(p)(2)) If spillage does occur, employees should take measures to control any vapors before restarting the engine. (1910.178(p)(3))

Aisles and walkways

Aisles must be marked and in good condition, with their widths maintained. (1910.22(b)(1)-(2)) They must also be clean and free of obstructions. (1910.22(b)(1)) Additionally, employees must ensure that fire aisles, access to stairways, and fire equipment are all clear. (1910.178(m)(14)) The aisles and passageways must be properly illuminated.

There should be safe clearance for equipment through all aisles and doorways. (1910.176(a)) Any pits and floor openings should be covered or otherwise guarded. (1910.22(c); .23(a)) Additionally, there must be standard guardrails present where aisle or walkway surfaces are elevated four feet or more above any adjacent floor or the ground. (1910.23(c)) Adequate barriers and warnings should be provided to prevent employees from stepping into the path of traffic where vehicles may be operated.

Housekeeping

Work areas, floors, walkways, and other surfaces should be clean and orderly. (1910.22(a), 1910.141(a)(3)(i)) Employees should check if there are any spilled materials or liquids present and if work surfaces are dry, and mats or grating should be used where drainage is needed. (1910.141(a)(3)(ii) 1910.22(a)(2)) Employees should use compressed air for cleaning under 30 pounds per square inch (psi). (1910.242(b)) Employees should also check for any accumulation of dust and/or other potential contaminants. (1910.141(a)(3))

Personal protective equipment (PPE)

Employees must wear foot protection anywhere there is risk of foot injuries in the workplace. (1910.132(a); .136(a)) They must also wear hard hats anywhere danger of falling objects exists. (1910.135(a)(1)) Companies should also ensure the use of protective goggles or face shields where there is danger of flying particles or corrosive materials. (1910.133(a)(1))

Approved safety glasses must be worn where there is a risk of eye injuries such as punctures, abrasions, contusions, or burns. 1910.133(a)(2) Employees should wear appropriate safety glasses, face shields, etc. while using hand tools or equipment which might produce flying materials or be subject to breakage. (1910.133(a)(1))

Companies must ensure that employees use required protective clothing or equipment as needed, and that it fits properly, is functional and in good repair, and marked with ANSI or ASTM International specifications. (1910.132(a), 1910.132(e), .135(b))

Postings

Required truck operating rules should be posted.

Recordkeeping

Any inspection and maintenance records should be kept on file.

Training

Only trained personnel should be allowed to operate industrial trucks, and the training methods used to train operators must be documented and meet the requirements specified in 1910.178(l).

Documentation

The Occupational Safety and Health Administration (OSHA) requires that forklift vehicles be inspected at least daily, or after each shift when used around the clock.