Forklifts and other PITs: Your top questions answered

So many companies, particularly warehouses and manufacturing, use forklifts and other powered industrial trucks (PITs) to move materials that it’s no surprise that 1910.178 is always found on OSHA’s Top 10 list of most frequently cited violations. Following are some common questions we receive on what’s required.

Q: Must we provide forklift operator training for each make and model?

A: Not necessarily, although you have to train on each “type” of truck. By “type,” OSHA means basic PIT differences — a sit-down rider truck vs. a stand-up truck, or an order-picker vs. a pallet jack. Refresher training is not required simply because an employee starts using the same type of truck made by a different manufacturer. Keep in mind, however, that the operator will need instruction on any aspects of the truck that are different, such as its controls.

Q: Is there a recommended speed for forklifts and other PITs operating in a manufacturing or warehousing facility?

A: OSHA doesn’t have specific speed limits set for the safe operation of a PIT. However, in determining what is a safe speed, OSHA takes a variety of factors into consideration, including the type of truck, the manufacturer’s limitations on the truck, the load being carried, adequate stopping distances, operating surface conditions, pedestrian traffic, and other safety issues.

While specific speed limits aren’t available, OSHA has said it would consider the totality of the circumstances surrounding the operation of the PIT in determining whether safe travel speeds are practiced at a workplace. Employers may reference consensus standards such as ANSI B56.1, “Safety Standard for Low Lift and High Lift Trucks” for assistance in determining safe travel speeds.

Q: Does OSHA require that the PIT key be removed when not in operation?

A: While most PIT training states that the key must be removed and controlled when the PIT isn’t in operation, this isn’t actually stated in 1910.178. The concern, however, is that an unauthorized person could attempt to operate the PIT. OSHA could cite the General Duty Clause. If the equipment is kept in a controlled area or if everyone is trained to be able to operate the PITs, the argument could be made that there isn’t a hazard, but that’s up to the discretion of the local OSHA jurisdiction. It can certainly be a company policy to remove the keys, but it’s not specifically required by OSHA.

Q: Does OSHA require PIT operators to have a valid driver’s license?

A: Federal OSHA has no requirement that a PIT operator have a valid driver’s license. OSHA does require that every PIT operator be trained and certified to operate the PIT in the workplace, and that the operator’s performance be evaluated on the provisions of 1910.178(l)(3) every three years. The employer must have a record documenting that the driver has successfully completed the training. That is the only operating “license” required by OSHA.

Q: Does the pre-shift forklift inspection need to be in writing?

A: No, OSHA doesn’t require the inspection to be in writing. However, many employers do require it in order to make sure it gets done (with a record) and to prove to OSHA that it’s being done.