Forklift Propane FAQs

OSHA does not have specific speed limits set for the safe operation of a powered industrial truck. However, in determining what is a safe speed, OSHA would take a variety of factors into consideration. These factors include, but are not limited to, the type of truck, the manufacturer's limitations on the truck, the load being carried, adequate stopping distances, operating surface conditions, pedestrian traffic, and other safety issues.

While specific speed limits are not available, OSHA has said it would consider the totality of the circumstances surrounding the operation of the powered industrial truck in determining whether safe travel speeds are practiced at a workplace. For additional assistance in determining safe travel speeds, OSHA says an employer could look to consensus standards such as ASME B56.1 Safety Standard For Low Lift and High Lift Trucks. For example, paragraph 4.3.2 of ASME B56.1 contains a Stopping Distance formula which may be useful in determining approximate theoretical stopping distances where certain variables are known. This information, along with other factors, can then be used to calculate a maximum safe speed.

Otherwise, the OSHA regulation addresses speeds in a few places, in a general manner:

• .178(n)(1) - All traffic regulations shall be observed, including authorized plant speed limits. A safe distance shall be maintained approximately three truck lengths from the truck ahead, and the truck shall be kept under control at all times.
• .178(n)(4) - The driver shall be required to slow down and sound the horn at cross aisles and other locations where vision is obstructed. If the load being carried obstructs forward view, the driver shall be required to travel with the load trailing.
• .178(n)(7) - Grades shall be ascended or descended slowly.
• .178(n)(8) - Under all travel conditions the truck shall be operated at a speed that will permit it to be brought to a stop in a safe manner.
• .178(n)(10) - The driver shall be required to slow down for wet and slippery floors.
• .178(n)(15) - While negotiating turns, speed shall be reduced to a safe level by means of turning the hand steering wheel in a smooth, sweeping motion. Except when maneuvering at a very low speed, the hand steering wheel shall be turned at a moderate, even rate.

OSHA does not have a requirement that forklift vehicles be equipped with a backup alarm or warning light (although these features are standard on most new equipment).

A forklift must have, at minimum, some type of sound-producing device that an operator can use at cross aisles and blind intersections where vision is obstructed to warn pedestrians and other forklift drivers that they are approaching. The "sound-producing device" mentioned in the Powered Industrial Truck standard is a horn.

However, OSHA cautions that certain operating conditions may require the use of additional warning devices, such as backup alarms. In those cases, the user would be responsible for making that determination and providing the necessary safeguards.

Federal OSHA does not specifically require employers to equip forklifts with portable fire extinguishers. However, depending on the hazards present in an area where the trucks travel, OSHA may have requirements for fire protection in that specific hazardous location. However, if the manufacturer equips its forklifts with fire extinguishers, the employer must maintain the extinguishers (according to the requirements of .157) and cannot remove/modify the equipment without written permission from the manufacturer. Note: There are various usage options and training requirements in .157 regarding portable fire extinguishers.

Also, the Liquefied Petroleum Gas standard at .110(e)(2) requires that LP-Gas fueled forklifts comply with NFPA 505- Standard for Type Designations, Areas of Use, Maintenance and Operation of Powered Industrial Trucks. Although the edition does not reference fire extinguishers, the edition addresses their use in Chapter 9, which states that where either the "authority having jurisdiction" or the end user requires an industrial truck to be equipped with a portable extinguisher, the location of the extinguisher must be in accordance with the truck manufacturer’s recommendation. The NFPA standard also says that industrial trucks can only be equipped with portable extinguishers if operators have been trained in their safe operation and use.

If the loads that are being bulldozed result in a hazardous condition because they are not stable or safely arranged, there would be a violation of OSHA’s requirements at §.178(o)(1). This work practice is potentially hazardous for the forklift drivers and for any pedestrians who may be in the area. The forklifts also are probably not designed to be used in a bulldozing manner. In addition, §.178(l)(3)(i)(M) requires that employees receive training on any operating instructions, warnings, or precautions listed in the operator's manual. If the truck's manual has warnings against these types of practices then this must be included in the training program content.

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In a letter of interpretation 04/11/ – Powered industrial truck modifications, OSHA stated: "29 CFR .178(a)(4) requires that 'Modifications and additions which affect the capacity and safe operation shall not be performed by the customer or user without manufacturers prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.' In the event that a powered industrial truck manufacturer has been sold to another company and is no longer in business, the user or customer must contact the purchasing company to request approval. In the event that the original powered industrial truck manufacturer is no longer in business and has not been purchased by another entity, the user or customer would be required to contact a Qualified Registered Professional Engineer for approval of such modifications and additions."

A front-end attachment would generally be an "addition" within the meaning of §.178(a)(4) that affects capacity and safe operation. Section .178(a)(5) assumes that the truck with the attachments will already be, "marked to identify the attachments and show the approximate weight of the truck and attachment combination at maximum elevation with load laterally centered." However, before a non-factory-installed attachment may be used, the employer must comply both with (a)(4), by obtaining the truck manufacturer’s written approval, and with (a)(5), by having the truck appropriately marked.

The OSHA Powered Industrial Truck regulation for General Industry, .178, does not specifically address steering knobs. However, there is an industry standard that Federal OSHA has often referenced: ANSI/ITSDF B56.1. This industry standard provides some fairly detailed information on steering knobs. In short, the ANSI standard does allow for steering knobs if certain criteria are met, and in some cases steering knobs may even be necessary, for example when steering must be accomplished with one hand. The equipment operating instructions should also be consulted. Note: OSHA's Construction standards do have requirements related to the use of steering knobs, in .602.

In most cases, commercial motor vehicles (CMV) are no longer required to chock trailer wheels when parking at loading docks. In an agreement between the Federal Motor Carrier Safety Administration (FMCSA) and OSHA, authority over CMV parking issues belongs to the FMCSA. Consequently, OSHA's wheel chock requirements in 29 CFR .178(k)(1) and .178(m)(7) of the Powered Industrial Truck standard no longer apply to commercial motor vehicles. This applies to any vehicle that:

• Has a gross vehicle weight rating or gross vehicle weight of at least 10,001 pounds, whichever is greater, or
• Is designed or used to transport more than eight passengers (including the driver) for compensation, or
• Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation, or
• Is used in transporting hazardous material in an amount requiring placarding under DOT regulations

The FMCSA's parking brake standard, 49 CFR 393.41(a), requires that every commercial motor vehicle manufactured since March (with the following four exceptions) be equipped with a parking brake system adequate to hold the vehicle or combination under any condition of loading.

However, agricultural commodity trailers, converter dolly, heavy hauler, and pulpwood trailers must carry and use chocking blocks to prevent movement when parked. Section 393.43(d) also requires that the trailer's brakes be applied automatically upon breakaway from the towing vehicle and maintained for at least 15 minutes.

OSHA instructed its regional offices that enforcement personnel are not to cite its wheel chocking requirements at 29 CFR .178(k)(1) or .178(m)(7) with regard to commercial motor vehicles.

Federal OSHA requires that forklift vehicles have to be inspected at least daily, or after each shift when used around the clock. You will find this requirement in the Powered Industrial Truck standard at .178(q)(7). OSHA does not require that forklift inspections be documented.

However, using an inspection checklist, either written or electronic, is a good idea for two reasons:

• You ensure that all essential features of the vehicle are inspected routinely, and
• It provides evidence to an OSHA inspector that the vehicles are being inspected as required by .178(q)(7).

Because daily inspection sheets are not required by OSHA, you should keep them according to whichever system works best in your company. Also, as part of your forklift program, it is a good idea to write a company policy stating something like "We retain forklift inspection sheets for six months." That way, you can keep whatever amount you decide, and it also will be proof to OSHA that your company is inspecting the vehicles (without retaining a huge stack of papers).

Note that some state programs might require retention. For example, in California, the daily inspection log can be considered a record of a scheduled inspection to identify unsafe conditions. In California, such records must be retained for one year under Cal/OSHA regulation §(b).

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