The first two articles of this series ( Part 1 / Part 2) discussed the requirements for training and certification of all forklift operators, and the knowledge and responsibilities that go with safe operations. Every operator also must be aware of the rules and requirements of forklift attachments.
The OSHA regulations clearly state in 29 CFR 1926.602(c)(1)(ii) that no modifications or additions which affect the capacity or safe operation of the equipment shall be made without the manufacturer’s written approval. This section goes on to state two other very important requirements:
1. If such modifications or changes are made, you are required to change the tags, decals, and instruction plates on the equipment.
2. In no case can the original safety factor of the equipment be reduced.
In clarifying what it means by modifications or additions, OSHA has cited examples that include using simple attachments like platforms and fork extenders. The manufacturer must approve virtually any attachment. The simple option is to use only attachments that have been made by the same manufacturer for use on their forklift. This involves some diligence to make sure you buy a forklift that has a suitable array of attachments available for your intended use. This includes counterweights and attachments that replace or extend the forklift. Using these attachments most likely changes the capacity of the lift. That requires you to note those changes on the equipment itself so that an operator is aware of the changes in capacity.
This brings us to all of the other field-fabricated attachments that we frequently see in the field. Are you really supposed to get written approval from the manufacturer any time you attach one of these simple field-fabricated devices to your forklift? The short answer is yes. That is the requirement listed in both the OSHA regulations and the ANSI standard. OSHA would consider the lack of written manufacturer’s approval to be a de minimis violation if the employer had obtained written approval from a qualified registered professional engineer after receiving no response or a negative response from a manufacturer. In other words, you must ask. But if you don’t get a response or they just tell you they will not give you permission, you can proceed as long as you enlist help from a qualified registered professional engineer.
If you want to fabricate your own attachments, you must enlist someone like a mechanical engineer or an engineer that is familiar with the ANSI Safety Standards for Powered Industrial Trucks. This standard is incorporated by reference into the OSHA regulations and it contains dozens of pages of manufacturing and testing requirements. It also requires all attachments to be secured to prevent separation from the forks.