Tackling OSHA’s Top 10 Citations: 1910.178 - Powered Industrial Trucks
The following is an excerpt from Tackle OSHA’s Top 10.
Hosted by Chief Safety Officer Jill James, you can listen to the webcast on demand.
Number six most cited is for forklift operation. Some of the things that I would look for with regard to forklifts, and in this particular picture, we're looking at a propane powered forklift. This, I would be looking to see that the propane tank itself was mounted correctly on the back of the forklift.
So how do you know if it's mounted correctly? Well, if we looked at where the gauge is on that propane tank, which would be on the right side, and we can't see it in this photograph, there'd actually be a gauge to read how full the tank was. So that gauge would want to be in the correct position to read it, but more than that, there's a little peg that's usually on the bottom of the forklift, and a little hole in the tank itself, that would seat onto that peg, and that would line it up to the correct position.
The reason that it's so important to have those mounted correctly is that there's a vent pipe that stretches through the entire length of that propane tank, and it twists up on the end. If you look at the end of a propane tank, you'll be able to see that vent pipe, and there's usually a little cap on the end of it, sometimes it's yellow, sometimes it's green, and that little rubber cap needs to be there, so it doesn't get occluded and full of dust or grime.
So it's a little, tiny pipe that then stretches through that whole cavity of that propane tank, and turns up at the end. So if you had that tank mounted upside-down, then the vent would actually be in the liquid space of the tank, rather than the vapor, or airspace of the tank, and you want it to be able to breathe. That's why it's really important to have those mounted properly, so that would be something that I would always look for on a propane powered forklift, specifically.
Then, depending on the state that you live in, some states will have requirements for internal carbon monoxide monitoring, particularly in states where maybe you close buildings up, things are heated in the winter, there's not a lot of ventilation. My home state of Minnesota actually has a specific state OSHA law that requires mandatory carbon monoxide testing any time an internal combustion engine is operating indoors. That would include a propane powered forklift, and it takes it to another step, where you can actually have what's called tailpipe emissions testing done on the forklift, so the motor can be adjusted to ensure that you're producing the least amount of carbon monoxide as possible.
So if you own a forklift like this, know that your forklift maintenance company in your local community, or maybe who you rent it from can do tailpipe emissions testing for you, and it can put your mind at ease that your forklift isn't poisoning your employees in your work area.
With regard to battery operated forklifts, some things to be mindful of is noting whether or not your employees have to add an electrolyte or water to the battery. That's not an uncommon practice, but it can expose your employees to battery acid coming back at them, so you want them to be in the right kind of personal protective equipment to prevent that from happening.
Then, any time you have a personnel device to lift people on a forklift, there's a couple of things to know. First of all, it should be manufactured for that purpose, and the basket itself needs to be tied into the mast of the forklift, so that it can't come off. Then it needs a complete guardrail system, and the guardrail system is a top rail, a mid rail, a kick plate on the bottom, and then the employee in this photograph, we're seeing that the employee is tied off inside of that unit. That's important to know and to do, if the forklift has the ability to tilt at all, and most forklift kinds, if you're familiar with them, will tilt down. So we want to use that fall protection system, the body harness, as like a leash, to prevent the employee from being ejected out of that guardrail system, should the forklift tilt.
The other piece is that some operator needs to be at the driver's seat of a forklift any time an employee's being held aloft in a personnel basket like this, so they can say, "Hey, get me down." So that's another piece to be asking about what your practices are in your workplace, and something that investigators would be looking for.
So some other hazards to consider would, again, be the difference between the battery and the propane powered forklifts, carbon monoxide, is it being mounted properly, the propane tank, and then being mindful of asking whether or not electrolytes or water is being added to batteries, and if the employee is doing that work in close proximity to an eye wash station and a shower station, so that if the worst happens and battery acid gets on them, do they have a short distance to go, to be able to have an eye wash station handy, as well as the right kind of personal protective equipment to protect them from that?
Then, again, seatbelt use. People ask me often, "Do we need to wear seatbelts?" Well, as the law is written, if you're on a smooth surface, then seatbelt use isn't mandatory unless you have a law that says so in your state, or perhaps it's a best practice in your company, but what's a smooth surface? You know, if you're going in and out of maybe a truck, with a loading dock, that's not necessarily smooth. Sometimes they are, depending on the dock, or if you're using it outside.
If a forklift, or maybe your particular facility, has a lot of projections or divots in the concrete of your plant, that could eject an employee from the forklift, then you'd want to be having them in a seatbelt. The whole idea of seatbelt use in forklifts is to keep the employee inside that rollover protective structure of the forklift, so if it begins to tip, you want that employee safely inside the cavity of that, rather than being ejected out where they can be crushed by the rollover protective structure. So that's the philosophy and reasoning behind that one.
So is forklift training required? Yes, it is.