OSHA’s powered industrial truck standard moved up from seventh place to sixth on the agency’s top ten most frequently cited standards for Fiscal 2013 (Oct. 1, 2012 to Sept. 30, 2013), with 3,340 offenses, up from 1,993 in 2012.

There are many types of powered industrial trucks. Each type presents different operating hazards. For example, a sit-down, counterbalanced high-lift rider truck is more likely than a motorized hand truck to be involved in a falling load accident because the sit-down rider truck can lift a load much higher than a hand truck.

Determining the best way to protect workers from injury largely depends on the type of truck operated and the worksite where it is being used. Employers must ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in 29 CFR 1910.178(l)(1).

Note: It is a violation of Federal law for anyone under 18 years of age to operate a forklift or for anyone over 18 years of age who is not properly trained and certified to do so.                        

The statistics

Each year in the United States, nearly 100 workers are killed and another 20,000 are seriously injured in forklift-related incidents [BLS 1997, 1998]. Forklift overturns represent about 25 percent of all forklift-related deaths and represent the leading cause of fatalities involving forklifts. Injuries also occur when forklift trucks are inadvertently driven off loading docks or fall between docks and an unsecured trailer. Workers can also be injured when struck by a lift truck, or if they fall while on elevated pallets and tines.

Forklift accidents also cause costly property damage, such as damage to overhead sprinklers, racking, pipes, walls, and machinery. In most cases, both employee injuries and property damage can be attributed to lack of safe operating procedures, lack of safety-rule enforcement, and insufficient or inadequate training.

The training imperative

The OSHA standard addresses specific training requirements for truck operation, loading, seat belts, overhead protective structures, alarms and maintenance of forklifts. Operator training should also address factors that affect the stability of a forklift – such as the weight and symmetry of the load, the speed at which the forklift is traveling, operating surface, tire pressure and driving behavior. Refresher training is required if an operator is found to be using the forklift in an unsafe manner, is involved in an accident or near miss, or is assigned a different type of truck.

Inspection and maintenance

Forklift mechanics are exposed to a variety of hazardous materials, according to OSHA. Chemicals pose a wide range of health hazards, such as irritation, sensitization, and carcinogenicity, and physical hazards, such as flammability, corrosion, and reactivity. Forklift operators often perform some of their own maintenance, such as refueling diesel or gasoline powered trucks, changing propane tanks on LPG trucks, or recharging and servicing electric batteries on electric forklifts. They may also change oil, antifreeze, or other fluids, and therefore, are exposed to a variety of hazardous chemicals.

OSHA’s standard states: “Industrial trucks shall be examined before being placed in service, and shall not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination shall be made at least daily. Where industrial trucks are used on a round-the-clock basis, they shall be examined after each shift. Defects when found shall be immediately reported and corrected.”

Protecting young workers

OSHA issued a safety and health information bulletin in 2009, “Protecting Young Workers: Prohibition Against Young Workers Operating Forklifts.” The bulletin is not a standard or regulation and creates no new legal obligations. It is advisory in nature.

The purpose of this safety and health information bulletin is:

1. To inform employers that youth employment regulations (29 CFR 570) promulgated under the Fair Labor Standards Act prohibit most employees under the age of 18 years from operating forklifts for non-agricultural operations;1

2. To remind employers that all forklift operators who are 18 years old or older must be trained and certified as competent to operate forklifts; and

3. To identify additional resources for employers to ensure a safe and healthful workplace for all workers.

Background

The Directorate of Science, Technology and Medicine was informed by the Atlanta OSHA Regional Office, the Boston OSHA Regional Office, and the Wage Hour Division (WHD) of the Employment Standards Administration (ESA) of two recent, fatal forklift accidents involving underage operators that occurred in warehouses in Georgia and Massachusetts. Both accidents involved operators under 18 years of age. Given the significant number of young workers employed, especially during the summer months, OSHA and WHD believe that it is important to remind all employers of the regulations that prohibit workers under 18 years of age from operating specified hazardous machines and equipment, including forklift trucks in non-agricultural operations.

Accident descriptions

Massachusetts accident: The forklift operator was a 16-year-old male hired as a summer helper to label bins and move stock by hand around the warehouse.

The warehouse has a forklift, and it was common practice to leave the forklift’s operating key in the ignition switch when the forklift was not being operated. Prior to the accident, the victim was observed operating the forklift several times, most recently on the morning of the accident. He was advised several times by a number of employees not to operate the forklift.

The victim was not trained nor was he certified as competent to operate the forklift.

There were no witnesses to the accident. However, it is believed that the victim boarded the forklift, without putting on the seatbelt, raised the forks with an empty pallet to a height of approximately 10 feet, and drove down the left side of the loading dock ramp. The ramp slopes away from the building at an angle of approximately 33 degrees on the left side near the street level.

There was a stack of empty pallets across the bottom of the ramp, and it appears that the victim was attempting to place the empty pallet on top of the stack before the close of business. With the forks raised to a height of approximately 10 feet on a 33 degree slope, the forklift’s center of gravity may have shifted, creating an unstable condition and causing the forklift to topple sideways. (Refer to 29 CFR 1910.178 Appendix A, for further discussion concerning stability of powered industrial trucks.) The victim was crushed under the truck.

Georgia accident: A foreman’s 15-year-old stepson was killed while the youth was operating a forklift at the warehouse.

The victim was being shown how to operate the forklift and was practicing picking up and moving empty pallets. He had just unloaded a pallet in the warehouse and had picked the empty pallet off the floor when he lost control of the forklift. The police investigator stated that the forklift “suddenly went backward, crashing open a closed loading bay door and drop[ping] four feet to the ground. The victim fell off [the forklift,] and the forklift landed on top of him.” The victim was pinned to the ground and sustained massive chest injuries.

The Fair Labor Standards Act

Regulations promulgated pursuant to the Fair Labor Standards Act prohibit individuals younger than 18 years of age from engaging in specified hazardous occupational activities. 29 CFR 570.58 - Occupations involved in the operation of power-driven hoisting apparatus (Order 7), paragraph (a) (5), specifically prohibits employees under 18 years of age from operating forklifts in non-agricultural employment.

Additional orders promulgated pursuant to the Fair Labor Standards Act prohibit operation of other machines that are hazardous to workers under 18 years of age. These orders include:

• Order 2, driving a motor vehicle and being an outside helper on a motor vehicle;

• Order 5, operation of power-driven wood-working machines;

• Order 8, operation of power-driven metal forming, punching, and shearing machines;

• Order 10, operation of power-driven meat-processing machines, including meat slicers;

• Order 11, operation of bakery machines;

• Order 12, operation of paper-products machines; and

• Order 14, operation of circular saws, band saws, and guillotine shears.

A complete list of occupational activities deemed to be unsafe for employees between 16 and 18 years of age can be found at: http://www.dol.gov/esa/regs/compliance/whd/whdfs43.htm.