OSHA 1910.178 basics for a new forklift owner

Buying the truck is the desk's job to help with. Running it is yours. If you employ people, the morning a used forklift arrives is the morning 29 CFR 1910.178 applies to how they use it. This page is a map of that standard for a new owner. It is not legal advice, and it is not a certification. Read the section, and if your state runs its own plan, read that too. OSHA lists state plans on its site.

The standard covers fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. It does not cover compressed-air or nonflammable-gas trucks, farm vehicles, or vehicles meant primarily for earth moving or over-the-road hauling. A rough-terrain forklift used as a forklift is still in the conversation. A dump truck is not. The price book is how we shop the iron. This page is what the employer owes after the invoice.

What "new" means in the design clause

Section 1910.178(a)(2) says all new powered industrial trucks acquired and used by an employer shall meet the design and construction requirements of ANSI B56.1-1969, which the regulation incorporates by reference. That sentence is about new trucks. A used purchase is a different sentence. Do not tell yourself the 1969 design clause is a free pass to ignore the rest. Training, inspection, capacity, fuel, and the operating rules apply to the trucks you put people on. The design standard has moved on at ITSDF, which now develops the B56 standards. The regulation still names the 1969 edition. When a letter or a manual cites a later ASME or ITSDF edition, notice which document you are in.

Training before anyone drives it

The employer has to make sure each operator is competent, shown by the training and evaluation in paragraph (l). Prior to letting an employee operate, other than for training, that training has to be done. Trainees may operate only under the direct supervision of someone who has the knowledge, training, and experience to train and evaluate, and only where the operation does not endanger the trainee or anyone else.

Training is a combination of three things, not a video alone. Formal instruction, such as lecture, discussion, computer learning, video, or written material. Practical training, meaning demonstrations and exercises by the trainee. And an evaluation of the operator's performance in the workplace. The person who trains and evaluates needs the knowledge, training, and experience to do it. OSHA's general industry training page says the employer owns the program. An outside trainer is allowed. A card from a parking-lot course, with no evaluation on your floor, is not the whole rule.

What the training has to cover

Paragraph (l)(3) splits topics into truck topics and workplace topics, except where the employer can show a topic does not apply. Truck topics include controls, engine or motor operation, steering, visibility with a load, fork and attachment limits, vehicle capacity, stability, the inspection and maintenance the operator will do, refueling or battery charging, and the warnings in the operator's manual. Workplace topics include surface conditions, load composition and stability, stacking, pedestrians, narrow aisles, hazardous locations, ramps, and closed environments where poor ventilation or poor maintenance could build up carbon monoxide or diesel exhaust.

A new owner who skips the manual has skipped a listed topic. Put the manual in the seat before the trainer arrives. If you bought a different type than the one your people already drive, say so. A sit-down and a reach truck are not the same evaluation.

Refresher, the three-year evaluation, and the paper

Refresher training is required when the operator is seen driving unsafely, is in an accident or a near-miss, gets an evaluation that shows unsafe operation, is assigned a different type of truck, or when a workplace condition changes in a way that could affect safe operation. Separately, an evaluation of each operator's performance is required at least once every three years.

Certification is not a plastic card from a website. The employer certifies that each operator has been trained and evaluated. The certification includes the operator's name, the date of training, the date of evaluation, and the identity of the person who did the training or evaluation. Keep that paper. "He drove at his last job" can satisfy the duplicative-training rule only if the prior training covers the required topics, fits this truck and this workplace, and the operator has been evaluated and found competent here.

The exam before the shift

Section 1910.178(q)(7) says industrial trucks shall be examined before being placed in service and shall not be placed in service if the exam shows any condition that adversely affects safety. The exam is at least daily. Round-the-clock use means an exam after each shift. Defects are reported and corrected immediately. Paragraph (p)(1) and (q)(1) take an unsafe truck out of service until it is restored. Repairs are done by authorized personnel.

OSHA's sample daily checklists are a guide for the training topic, split between electric and internal combustion, and they are not exhaustive. Build the list from the manual for the truck you bought. The purchase walk on our method page is how the truck got in the door. The daily exam is how it stays there. They are not the same document.

Rules that surprise new owners

• Nobody stands or passes under the elevated part of a truck, loaded or empty. That is 1910.178(m)(2).
• Unauthorized riders are not allowed. If riding is authorized, there has to be a safe place to ride.
• An unattended truck has the load fully lowered, controls neutralized, power shut off, and brakes set. Wheels are blocked on an incline. Unattended means the operator is 25 feet or more away while the truck is still in view, or the operator has left and the truck is not in view.
• If the operator is dismounted but within 25 feet and the truck is still in view, the load is lowered, controls are neutralized, and the brakes are set.
• An overhead guard is required as protection against falling objects. OSHA notes that it is meant for small packages and the like, not for the impact of a falling capacity load.
• Only loads within the rated capacity are handled. Attachments change that number. Read capacity plates before someone hangs a clamp on a truck plate that does not mention a clamp.
• Fuel tanks are not filled while the engine is running. A leak in the fuel system means the truck stays down until the leak is fixed.
• Nameplates and markings stay in place and stay legible. That is 1910.178(a)(6).

Carbon monoxide is an operating rule

If you bought LP or diesel because the ad was cheaper than electric, paragraph (i) still applies. Carbon monoxide from truck operations cannot exceed the limits in 1910.1000. The fuel guide walks through ventilation, LP handling, and one OSHA accident summary where indoor LP trucks were the exposure. Do not file that under "the seller's problem." Once your people run the truck, it is your building.

What to have on the dock the day it arrives

1. The operator's manual, and the data plate that matches the attachment on the truck.
2. A trainer who has actually run this type, and time for practice on your floor, not only a video.
3. A written certification sheet with name, training date, evaluation date, and the trainer's name.
4. A daily exam sheet built from the manual, and a rule that a failed item parks the truck.
5. A plan for fuel or charging that matches 1910.110 if you are on LP, or a real charger and a place to charge if you are on electric.

If you do not own the truck yet, none of this is a reason to stall a clean buy. It is a reason to put training and the plate on the same list as freight. Request the truck when the job is real. Ask the yard for the manual in the deal. We grade iron. We do not certify your operators, and we do not sell the truck.