By Chris E. Marsh
One of the most potentially dangerous pieces of equipment at a precast plant is the powered industrial truck, a category that includes forklifts, lift trucks and hand trucks. OSHA Section 29 CFR 1910.178 addresses this issue and gives the business owner three areas of concern that must be addressed. Sections A through K address requirements for the workplace, while Section L addresses operator training, and Sections M through Q address worker safety. Here we will outline the areas that should be addressed in the operation of powered industrial trucks and the training requirements for operators.
Section L – Operator Training
Prior to January 1999, Section L of the OSHA standard consisted of only three short sentences. The problem with such brevity was that it gave too much leeway for interpretation by the company in operator training. When Section L was changed, OSHA cleared up those operator training questions.
Section L states that the company must ensure all operators are competent through successful completion of a specific training course. In addition, the employer must ensure the operator has successfully completed the training program before allowing him or her to operate the vehicle, except for training purposes.
During training, the employee may operate the equipment under only two instances: when under the direct supervision of persons who have the knowledge, training and experience to train operators and evaluate their competence, and when the operation of the powered industrial truck does not endanger the trainee or any other employee.
The training must consist of a combination of formal instructional methods, such as a lecture, discussion video tape, written material or interactive computer learning. There should also be practical training, such as demonstrations performed by the trainer and exercises performed by the trainee.
The third part of this training requirement is an evaluation of the operator’s performance in the workplace. All operator training must be conducted by persons having the knowledge, training and experience to train powered industrial truck operators and evaluate their competence.
Steve Wolszczenski of Terre Hill Concrete Products directs an effective training curriculum at his company. First is the classroom training that covers safety concepts and compliance requirements. Some of the main topics include preinspection, the load centers and the stability of the forklift or other powered industrial truck, as well as other compliance topics required by the standard. Designated instructors then provide hands-on training in operation of the vehicle that includes actually driving in the work environment. Next, Terre Hill issues a temporary permit to the drivers that is good for two to three weeks, depending on the driver’s previous experience. At the conclusion of this “probationary” period, instructors perform an operational checklist-style evaluation of the driver to determine if he or she qualifies for a three-year license. This evaluation is conducted for each powered industrial truck the operator will be certified to operate.
Training program content
Powered industrial truck operators must receive training in the topics listed below except those the employer can show are not applicable to the safe operation of the truck in that particular workplace. However, this may be difficult to prove and it would probably be more advantageous to train in all areas. Training must include:
1. Truck related topics: (a) operating instructions, warnings and precautions for the types of truck the operator will be authorized to operate; (b) differences between the truck and an automobile, which may include information from Appendix A of the standard concerning the stability triangle and what causes tipovers and spills (see the sidebar “The Stability Triangle”); (c) truck controls and instrumentation; (d) engine or motor operation; (e) steering and maneuvering; (f) visibility, including restrictions due to loading; (g) fork and attachment adaptation, operation and use limitations; (h) vehicle capacity; (i) vehicle stability; (j) any vehicle inspection and maintenance that the operator will be required to perform; (k) refueling and/or charging and recharging batteries; (l) operating limitations; and (m) any other operating instructions, warnings or precautions.
2. Workplace related topics: (a) surface conditions where the vehicle will be operated; (b) composition of loads to be carried and load stability; (c) load manipulation, stacking and unstacking; (d) pedestrian traffic; (e) narrow aisles and other restricted places where the vehicle will be operated; (f) hazardous (classified) locations where the vehicle will be operated; (g) ramps and other sloped surfaces that could affect the vehicle’s stability; (h) closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust; and (l) other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation.
3. The requirements of this OSHA section.
Refresher training and evaluation
Refresher training in the relevant topics must be conducted under any of the following circumstances:
- The operator has been observed to operate in an unsafe manner
- The operator has been involved in an accident or near-miss
- The operator has received an evaluation that reveals he or she is not operating the truck safely
- The operator is assigned to drive a different type of truck
- A condition in the workplace changes in a manner that could affect safe operation of the truck
This section also states that an evaluation of each powered industrial truck operator’s performance must be conducted at least once every three years. Wolszczenski stated that his trainers perform hands-on evaluations with operators before issuing permanent licenses. Then, unless the driver qualifies on another piece of equipment, that permit is good at Terre Hill for three years, when the company performs another evaluation with the operator to maintain licensing.
The employer should be aware of two other items in Section L. If an operator has already received training and has been evaluated and found to be competent to operate the truck safely, duplicative training can be avoided (see the sidebar “Avoiding Duplicative Training”). Also, the employer must keep proof of certification for each operator to include the operator’s name, the date of training, the date of the evaluation, and the identity of the person performing the training or evaluation.
“Section A – General Requirements” defines the category of powered industrial trucks (see the sidebar “What Is a Powered Industrial Truck?”).
“Section B – Designations” and “Section C – Designated Locations” are concerned with the designations of powered industrial trucks and where they may be operational. For example, the trucks are designated as either G, D, E or LP. This designation refers to the fuel used to power the truck (G = gas, D = diesel, E = electric and LP = liquefied petroleum gas). OSHA also adds additional letters to help the user determine where a truck is safe to operate used and where it would be dangerous. For example, the EX designation is an electrically powered unit that is designed, constructed and assembled so that the unit may be used in atmospheres that contain flammable vapors or dusts.
Section C provides a lengthy description of where different types of trucks can be used. Your employees should read this section if your operation handles any hazardous materials or chemicals, or works in hazardous atmospheres.
“Section D – Converted Industrial Trucks” covers vehicles converted from gas operation to LP, and “Section E – Safety Guards” discusses the use of safety guards on the vehicle. “Section F – Fuel Handling and Storage” specifies that liquid fuel and LPG fuel will be stored and handled in accordance with the National Fire Protection Association (NFPA) and is incorporated into this standard by reference.
“Section G – Changing and Charging Storage Batteries” is a more detailed section. There are specific statements that must be followed. Battery charging operations must be located in a place specifically designated for that purpose. The area must be equipped to protect the charging equipment from being damaged by trucks. There should also be an eyewash station and shower within the immediate area as well as adequate ventilation, fire protection equipment and facilities for washing away spilled electrolyte.
The standard continues with sections on lighting (H), carbon monoxide (I), dockboards/bridge plates (J), and trucks and railroad cars (K). The two main ideas concerning trucks and rail cars are to make sure the wheels cannot move and to use jacks when necessary.
Section M – Operator Safety
Section M concerns operator safety while operating a powered industrial truck. There are 14 parts to this section, and although only three will be discussed here, your employees should be familiar with the entire section.
Parts 2 and 3 state that no person should be allowed to stand under or pass beneath the raised forks of the truck and that no one but the operator is allowed on the truck. A truck can be either attended or unattended when the driver dismounts (Part 5). If unattended, the brakes must be set, the load lowered, the motor shut off and the controls neutralized.
The truck is unattended when either the vehicle is not within the operator’s view, or the vehicle is within view of the operator and more than 25 feet away. If the vehicle is within view of the operator and less than 25 feet away, it is attended and the power can be left on, but everything else concerning the unattended status must be done.
Lastly, fire aisles, access to stairways and fire equipment must be kept clear when the vehicle is parked.
Section N – Traveling
Section N provides the rules for actually driving the powered industrial truck. Any traffic regulations in the plant or work area must be observed, including the speed limit. No horseplay or reckless driving is to be allowed, and the operator must control the vehicle in a safe manner.
The driver must be required to slow down and sound the horn at all cross aisles or any other areas where vision is obstructed. If the load restricts the view, the driver must travel with the load trailing. The driver must have a clear view of the path of travel. When ascending or descending grades of more than 10 percent, the load must always be on the uphill side with the load tilted back.
The other 10 parts to this section also are directed to the travel and movement of the powered industrial truck and should be studied by each operator.
Section O – Loading
The loading section is short but very important. Loading is directly responsible for many accidents involving operators, bystanders or property. The only time a load is to be carried is if it can be safely handled or arranged. If the load is off center, the operator must exercise extreme caution.
Only loads within the rated capacity of the vehicle can be carried. In other words, if you have a 5,000-pound forklift, you cannot exceed 5,000 pounds when loading. Trucks with attachments must be handled as partially loaded when not handling a load. The lifting mechanism must be placed under the load as far as possible with the mast carefully tilted back to stabilize the load. Use extreme care when tilting the load forward or backward, particularly when high tiering. Tilting a load forward while elevated is prohibited except to pick up a load.
Section P – Operation and Section Q – Maintenance
Sections P and Q both mention that any time a defect or maintenance problem of any kind arises in a powered industrial truck, the operator is to record the problem and report it to a supervisor or management. This is very important, because any type of problem with the vehicle could cause injury or death or, at minimum, property damage.
This is the main thrust of the two sections. The rest covers common procedures such as unhooking the battery to do electrical work; making sure the truck is not altered by placing knobs or levers in different places than originally placed; and making sure that the first person to use the powered industrial truck on each shift performs a maintenance checkup and walk-through to determine if there are any problems. Again, read the final sections of the standard for the complete list of parts to each section.
OSHA mandates that management have some very specific rules concerning powered industrial trucks. This in turn gives operators specific rules to follow to safely operate the vehicle. If both parties work together to follow the regulations and use common sense, the possibility of injury, death or property damage will be minimized in your operation.
Chris E. Marsh, who owns Ogeechee Training Services in Statesboro, Ga., helps businesses come into compliance with OSHA regulations and also provides them with employee risk management services.