Editor’s Note: This is the second of three parts.
In part 1 of this three-part series (December 2014, page 20), we discussed the OSHA requirements for training and certifying forklift operators. This second part focuses on inspections and proper onsite use.
We tend to use the forklift as a catch-all machine, our “go to” piece of equipment when we need something moved, lifted, or unloaded. But not all forklifts are created equal or are up to every task. This is one primary reason that forklift operators are required to be trained and certified. Changing site conditions and equipment demands are why this training is required to be site- and machine-specific. This often means some additional training may be required when presented with new conditions.
Take the typical scenario of arriving on the job and walking up to the forklift that the rental company just dropped off. The following questions immediately pop up:
1. Who makes sure that everything works on this machine?
2. Who makes sure this machine is the same (or similar enough) as the one that the operator was trained to operate?
3. Who makes sure the machine is safe and can take it out of operation if it is not?
4. Who verifies the adequacy and compatibility of any attachments that you plan on using (fork extenders, spreaders)?
5. Who makes sure the equipment is suitable for the intended task?
The quick answer to all of these questions is simple: the employer. The practical answer involves that trained and certified operator. A company often assumes the machine that arrived on their jobsite is properly maintained, safe and ready to use, and adequate for the task. Whether the equipment was delivered from a rental yard, or from the company’s own equipment yard, it should always be inspected before each use.
The OSHA regulations pertaining to forklifts in construction (29 CFR 1926.602) incorporate the ANSI Safety Standard for Powered Industrial Trucks, B56.1-1969. All powered industrial trucks must meet the applicable requirements of design, construction, stability, inspection, testing, maintenance, and operation contained in this standard. That imposes lots of requirements on the user that the company and the operator must be familiar with.
OSHA’s website has a number of official Letters of Interpretation pertaining to these issues. In terms of inspections and operation, all of this information combines to impose the following:
1. Forklifts must be inspected before they are used, and then daily (or before each shift if used around the clock) thereafter to ensure they are operating properly and safely.
2. The inspections must be done by a qualified and competent person, such as the certified forklift operator.
3. If a forklift is in need of repair, defective, or unsafe, it must be taken out of service until it has been restored to a safe operating condition.
4. The forklift cannot be used in any manner prohibited by the manufacturer.
5. The manufacturer must approve any attachments that affect its capacity or safe use.
These are the employer’s responsibility, making it critical that you include this training and knowledge in your forklift operator certification programs. The operator should have the knowledge to evaluate the site-specific conditions and determine the adequacy of the equipment. Make sure your operators know they should inspect the equipment before using it. Do not rely on it just being delivered from the shop. Make sure your operators know that they cannot use a defective piece of equipment with the intent of notifying you when the shift is over. They must report it and take it out of service immediately.
Where’s the operating manual?
When renting equipment, make sure you know what they are going to deliver and make sure the operating manual is in the cab. Additional training may be necessary onsite if you use a new piece of equipment or are going to use the equipment in a manner that is different from what the operator is used to.
The last two items in our list are widely abused. OSHA regulations and ANSI standards clearly state that attachments must be approved by the manufacturer and that forklifts cannot be used in any manner prohibited by the manufacturer. Take for example, the hoisting of personnel. On one hand, the OSHA regulations list several requirements that must be followed when using a forklift to hoist personnel. However this does not mean every forklift can be used to hoist personnel if those requirements are followed. If the manufacturer states that its machine cannot be used to hoist personnel, that is the governing rule.
Forklift attachments are used frequently in our industry. OSHA and ANSI requirements must be followed to ensure they are used safely. In the next column we will explore these requirements in depth, including conditions that have been specifically addressed by OSHA in published Letters of Interpretation, and attachments that effectively turn the forklift” into a crane, ushering in more and extensive new requirements.