Powered Industrial Trucks
Introduction
It’s often difficult to identify all the different environmental regulations that apply to an operation. You can use J. J. Keller’s Related Program Index (RPI) to help you understand when requirements from other agencies or compliance programs apply. The RPI uses J. J. Keller’s broad regulatory knowledge and experience to identify all your related requirements.
If you operate powered industrial trucks(PIT), you should consider ...
OSHA Powered Industrial Truck Standard
This safety standard applies to most types of material handling equipment that is powered for horizontal movement. This includes forklifts, order pickers, powered pallet jacks, yard jockeys, stand-up and narrow aisle lift trucks, to name a few. The standard does not cover over-the-road haulage trucks and earth-moving equipment that has been modified to accept forks. In addition, the standard does not apply to scissor lifts or aerial lifts (some of those are covered by other OSHA standards, however).
Per the standard, employers are required to identify all PITs in the workplace, follow capacity ratings, provide operator training and evaluation, require equipment inspection, remove unsafe equipment, set and enforce operating rules, provide designated areas for battery charging/changing operations, and more.
Regulatory citation
- 29 CFR 1910.178 — Powered industrial trucks
Aboveground Storage Tank Systems
Facilities with PITs often store fuel for those units in aboveground tanks. Regardless of fuel type (i.e., propane or gasoline) stored in the tank, a variety of regulatory requirements may apply to tank(s). ASTs are regulated at the federal level in a somewhat piecemeal way. Consequently, it is necessary to look in several different places for AST requirements:
- OSHA requirements, in 29 CFR 1910.106, address ASTs that contain flammable or combustible liquids. The rules apply to liquids with flashpoints below 200°F.
- Storage of petroleum products (oils and fuels) in an AST, may be regulated under the Spill Prevention, Control and Countermeasure (SPCC) regulation. SPCC applies when a facility has petroleum product storage capacity of greater than 1,320 gallons in aboveground containers (55 gallons or greater) or storage in completely buried storage tanks greater than 42,000 gallons in containers 55 gallons or greater. Last, SPCC applies to any facility that could be reasonably expected to discharge oil in quantities that may be harmful into navigable waters or adjoining shorelines.
Additionally, most AST regulations are found at the state and local level. Check with your state and local agencies to see if there are more stringent AST requirements that you need to know about.
Regulatory citations:
Related Compliance Network subjects:
- Tank Systems (SMS topic: Tank systems)
- Oil Spill Prevention
Emergency Planning and Community Right-to-Know Act
Emergency Planning and Community Right-to-Know Act (EPCRA) was first written to reduce the likelihood of chemical related disasters in the U.S. The Community Right-to-Know provisions of EPCRA, increase the public access to information about chemicals in their community. EPCRA has five major provisions, all of which could apply to an operation with PITs, and the most likely applicable requirements are found in the hazardous chemical storage reporting section (also known as Tier II).
The Tier II section of EPCRA requires facilities handling or storing any hazardous chemicals in an amount equal to or greater than their threshold levels to file an inventory report. EPCRA does not have a chemical list, rather it covers all hazardous chemicals, means any hazardous chemical as defined by OSHA, with some extremely hazardous substances having lower reporting thresholds.
The batteries in just one PIT can be large enough to trigger EPCRA Tier II reporting for hazardous chemicals including sulfuric acid. Additional Tier II reporting, depending on volumes, can be triggered by fuel storage, spare battery storage, and hydraulic fluids. Regulatory citations:
Related Compliance Network subjects:
Waste Generation and Disposal
PIT maintenance activities can generate a variety of regulated wastes. These commonly include waste rags, spent batteries, empty containers, waste tires, and more.
Solvent-contaminated industrial rags used to clean up parts, equipment, or small spills, are contaminated with certain solvents and must be managed according to the specific exclusions in 40 CFR 261.4. This management includes storing rags in closed, non-leaking containers, labeling containers, removing free liquids, sending wipes off-site within 180 days, and recordkeeping requirements.
Federal regulations identify five specific categories of materials that can be managed as universal wastes: batteries, pesticides, mercury-containing equipment, lamps, and non-empty aerosol cans. Universal wastes must be stored universal wastes in appropriate containers, be collected in containers labeled with the words “Universal Waste” and the type of universal waste (e.g., waste batteries, waste lamps), and be shipped offsite within one year.
Regulatory citations:
Related Compliance Network subjects:
- Waste (SMS topics: universal waste, waste rags, special waste)
Hazard Communication
The Occupational Safety and Health Administration’s (OSHA) hazard communication, or HazCom, standard (HCS) covers ‘‘any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.” Most chemicals in the workplace, including those used in PIT maintenance, have at least some hazard potential and will therefore be covered by HCS.
Regulatory citations:
Related Compliance Network subjects:
Air Programs
The operation of PITs can trigger several air-related regulations and reporting. The first of these is greenhouse gas (GHG) reporting. While most GHG mandatory reduction regulations at the federal and state levels exempt mobile source emissions, some do require they be included in reporting. Mobile source GHG emissions, including those from PITs, should be included in voluntary sustainability tracing and reporting.
Second, Title II of the Clean Air Act addresses air pollutants from mobile sources including aircraft, ships, nonroad vehicles, nonroad engines, and fuels. Some state air regulations have registration programs that may include PITs.
Regulatory citations:
- 40 CFR 98
- 40 CFR Parts 59, 80, 85, and 86
- 49 CFR Part 523, 531, 533, 536, and 537
- 40 CFR Part 600
- 40 CFR Part 1036, 1037, 1039, 1042, 1048, 1054, 1065, and 1066
Related Compliance Network subjects:
- Air programs (SMS topic: greenhouse gases, mobile emission sources)