Sometimes we can find the most concise explanations from OSHA in these Extensions of the Office of Management and Budget's (OMB) Approval of Information Collection (Paperwork) Requirements.  This week OSHA posted an extension notice regarding the paperwork requirements found in 1910.178 Powered Industrial Trucks Standard.  It is in this posting that OSHA does such a nice job stating what has to happen and how it must be documented when we want to modify a PIT in a manner that affects its capacity and safe operation...

(emphasis added by me)

Paragraph (a)(4) of the Powered Industrial Trucks Standard REQUIRES employers to obtain the manufacturer's WRITTEN approval before modifying a truck in a manner that affects its capacity and safe operation. 

If the manufacturer grants such approval, the employer MUST revise capacity, operation, and maintenance instruction plates, tags, and decals accordingly.

For front-end attachments NOT installed by the manufacturer, paragraph (a)(5) mandates that employers provide a marker on the trucks that identifies the attachment, as well as the weight of  BOTH the truck and the attachment when the attachment is at maximum elevation with a laterally centered load.

Paragraph (a)(6) specifies that employers MUST ENSURE that the markers required by paragraphs (a)(3) through (a)(5) remain affixed to the trucks and are LEGIBLE.

The other "paper work" requirements of the standard are:

  • Paragraphs (l)(4) and (l)(6) of the Standard contain the paperwork requirements necessary to certify the evaluation and training provided to powered industrial truck operators. Accordingly, these paragraphs specify the following requirements for employers.
  • Paragraph (l)(4)(iii) - Evaluate each operator's performance at least once every three years.
  • Paragraph (l)(6) - Certify that each operator meets the training and evaluation requirements specified by paragraph (l). This certification must include the operator's name, the training date, the evaluation date, and the identity of the individual(s) who performed the training and evaluation.

Requiring labels (markings) on modified equipment notifies workers of the conditions under which they can safely operate powered industrial trucks, thereby preventing such hazards as fires and explosions caused by poorly designed electrical systems, rollovers/tipovers that result from exceeding a truck's stability characteristics, and falling loads that occur when loads exceed the lifting capacities of attachments.

Certification of worker training and evaluation provides a means of informing employers that their workers received the training and demonstrated the performance necessary to operate a truck within its capacity and control limitations. 

By ensuring that workers operate only trucks that are in proper working order, and do so safely, employers prevent possible severe injury or death of truck operators and other workers who are in the vicinity of the trucks. 

Finally, these paperwork requirements are the most efficient means for an OSHA compliance officer to determine that an employer properly notified workers about the design and construction of, and modifications made to, the trucks they are operating, and that an employer provided them with the required training.

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