Although the recession is beginning to ease, a lot of companies have been forced to cut back, to do more with fewer people, and to assign many employees to new jobs they may have never done. With this in mind, you can see where OSHA would have reason to make sure that these employees are being protected in the workplace. Since the government is also looking for increased revenue streams, it is highly likely that we will see an up-tick in OSHA inspections and enforcement of regulations. In fact, it was announced this month that OSHA will be increasing inspections in the Southeast United States.
However, when we think of OSHA and material handling, we all too often think simply of operator training. But the guidelines for keeping forklift operators and pedestrians safe extend far beyond the scope of training. However, before we address these areas of concern, let's take a quick look at some of the lesser-known conditions for which operator training is required:
- When an operator has been observed to operate the vehicle in an unsafe manner 1910.178(I)(4)(ii)(A)
- The operator has been in a near-miss accident 1910.178(I)(4)(ii)(B)
- The operator has received an evaluation that reveals that the operator is not operating the truck safely 1910.178(I)(4)(ii)(C)
- The operator is assigned to a different type of truck (1910.178(I)(4)(ii)(D)
- A condition in the workplace changes in a manner that could affect safe operation of the truck 1910.178(I)(4)(ii)(E)
During the recession, forklifts have been shuffled and employees re-assigned. Making sure they are up to speed with the new conditions is essential for a safe facility and compliance with OSHA regulations. Now, let's look at some of the conditions that could put your OSHA inspection in peril.
Daily Inspections - Are your forklifts being inspected and documented before each shift by your operators? Visit our Training page and download our free Pre-Shift Inspection Checklist for IC forklifts HERE, and electric forklifts HERE. Listed below are a few of the key components to inspect on a daily basis before operating your lift truck.
Horns - Are all the horns working on your lift trucks? OSHA requires truckers to "sound the horn at cross aisles and other locations where the vision is obstructed." 1910.178 (n) (4) To further protect employees and ensure a safe facility, back-up alarms are a best practice. Are your lifts equipped and are they all in good working order?
Seat Belts - Are your lift truck's seat belts all in good working order?
Tires - Chunked tires or severely worn tires present a significant hazard for operators and pedestrians alike.
Gauges - Are all the gauges and indicators in good working order on each of your lift trucks? This includes hour meters, oil pressure, temperature and any other gauge installed by the manufacturer.
Forks - When was the last time your forks were inspected for wear, cracks or other unsafe conditions? See our previous Feature Article Proper Fork and Chain Inspections.
Lighting - Are your forklifts appropriately equipped with working lights, where lighting is less than 2 lumens per square foot? 1910.178 (h) (2). This generally means all forklifts that enter a semi-trailer while equipped with an opaque or solid roof will require lights on your lift truck. To reinforce facility safety and provide additional protection, safety lights are recommended on the rear overhead guard.
Fire Extinguishers - Depending upon the class of potential fire, employees must be provided with fire extinguishers so that their distance from an extinguisher is no more than 50 ft (class B hazard area) to 75 ft (Class A and D). In the absence of an appropriate sprinkler system, forklifts that travel out into a facility without adequate fire extinguisher coverage should be equipped with an extinguisher, particularly if you use IC engine trucks. If using IC it is always a best practice to minimize facility hazards by equipping your lift trucks with a working fire extinguisher.
Battery Changing - Is your battery changing station safe? If you are using a crane, has it been inspected recently for safety? Do you have the appropriate personal equipment for changing batteries (gloves, goggles etc...), and are there appropriate warning signs?
Wheel chocks - If your forklifts are parked on an incline, not only must the brakes be set and the engine in neutral, but the wheels must be chocked. Does your facility have wheel chocks at locations (dock ramps) where these are required? OSHA does not give an inclined degree, so think conservatively. It is better to be over-prepared than under-prepared. In addition to wheel chocks for forklifts, your facility must provide wheel chocks for semi-trailers to keep them secured against the dock during loading and unloading. Are all your semi-trailer wheel chocks available and in good working condition?
Lock-outs - If a forklift is in need of repair, it must remain out of service until repairs are made. How do you ensure that this forklift is not being used by an unsuspecting employee? Lock-out kits prevent forklifts from being used by employees until they are repaired and returned to service.
Remember, when it comes to operating a lift truck, an operator must:
- Be trained and authorized to operate the specific lift truck to be used
- Read and understand the operator's manual
- Not operate a faulty lift truck (requiring a pre-shift inspection)
- Not try to repair a lift truck unless trained and authorized to do so
- Have the overhead guard and load backrest extension in place
During operation, a lift truck operator must:
- Wear a seat belt
- Keep entire body inside truck cab
- Never carry passengers or lift people
- Keep lift truck away from people and obstructions
- Travel with lift mechanism as low as possible and tilted back
- Allow safe stopping distance and come to a complete stop before leaving operator compartment
- When coming to a stop, an operator must:
- Completely lower forks or attachments
- Shift into neutral
- Turn key off
- Set parking brake
This is just a partial list. OSHA will want to be satisfied that you have in place a solid program for ensuring a safe forklift fleet. A good Preventive Maintenance Program (PM) with a responsible partner will help keep your forklift fleet in peak operating condition, and your operators and pedestrians as safe as possible.
We hope this list helps you to understand that when it comes to a safe forklift fleet, operator training is just one facet of a safe and productive working environment. If you want a partner that will work with you to make sure you achieve this, Apex Material Handling should be your next call.
When it comes to forklift safety, parts and preventive maintenance programs, no company beats Apex. Our team of professionals has been doing it for decades! We would appreciate the opportunity to earn your business.