Disclaimer: The 2020 SSG emphasis program is designed for owners and managers to ensure they are adhering to, and maintaining the technical elements of their OSHA compliance and safety program. Although some may be used for employee training, it was not designed as such. Check out the link below to gain access to our employee-based, OSHA-compliant trainings on numerous topics.
This is part 2 of our series on forklifts, and it’s packed full of regulations that are unknown and unnoticed! We dig into the UPDATED ANSI-B56.1-2016 and 2018 standards, as well as the OSHA 1910.178(q) standards. We address:
• OSHA’s adoption of the ANSI-B56.1 standard
• Removing forklifts from service
• Who’s authorized to work on forklifts
• What each pre-shift inspection should be assessing
• Who to outsource your forklifts mechanical needs to
• What OSHA considers non-compliant modifications & repairs
• The requirements of making modifications
• Fork-specific inspections (forks ONLY)
• Improving your forklift operations with the ANSI standards
• The reason why documented inspections are important
• And more foundational knowledge to keep you and your team safe
We appreciate each of you that make an investment in your safety program, and we hope you find this information valuable.
FULL Video Transcript
2020 Emphasis Program Forklifts Week 6 – Maintenance
Welcome back to week 6, and part 2 of our walk through the OSHA regulations on powered industrial trucks, aka forklifts. Last week we went deep into the OSHA training requirements, the things they’re checking for within your training program, and we answered a ton of commonly asked, but often commonly incorrectly answered…questions. So be sure to go back and check that out. You can sign up for free at training.safetyconsultingnow.com and receive access to all of these 2020 emphasis programs, as well as sign up for our premium content that is PACKED full of OSHA-required training and toolbox talk style micro-trainings. I promise you, reaching your teammates in a unique way that’s genuine and educational is well-worth the minimal investment. Plus, it gives you an opportunity to mix up your training routine. So check that out and if you have any questions on that whatsoever, you can email me at NOW@summitsafetygroup.com and we’ll get you taken care of.
So as we get into the maintenance portion of this standard, it’s important to gain a little background on where OSHA adopts these regulations from. As is the case with many of the OSHA standards, they are not the experts in the tools or equipment they are helping to regulate regarding safe operation, but rather they act as the governing body that enforces what the experts in these fields say should be the standard. As is the case with forklifts, OSHA will adopt what the American National Standards Institute (or ANSI), the American Society of Mechanical Engineers (ASME), and more recently, the Industrial Truck Standards Development Foundation (ITSDF), which is an ANSI-accredited standards-developing organization. And an even deeper history lesson for you all, in June, 1950, ASA (now called ANSI) approved a Safety Code for Industrial Trucks called ASA B56.1-1950. So, coming back to the ITSDF, it was formed in 2005 to administer the B56 Standards Committee, and continue getting experts in the field to weigh in on the current forklift standards and what may need to be modified. The standards we are operating from in this video are primarily found in B56.1-2016 and 2018, which are the most recent revisions at the time of this video. But listen, I do want to clarify that this video is NOT intended to be a training for your team on the detailed maintenance of your forklift, but rather, my goal is to highlight some of the standards and explain what OSHA will be looking for in these particular cases.
First and foremost, as stated in OSHA 1910.178(g)(1) when forklifts are in need of repair or maintenance, they should be immediately removed from service. As it states in the ANSI ITSDF B56 5.5.1 standard on operator care of the forklift, “at the beginning of each shift and before operating the truck, check its condition, giving special attention to the following: (which by the way would make a great pre-operational checklist for your team), and that is as follows:
(a) condition of tires
(b) tire inflation pressure
(c) warning and safety devices
(g) lift and tilt systems
(h) load-engaging means
(g) chains and cables
(h) limit switches
(j) steering mechanism
(k) fuel systems
(l) additional items, attachments, or special equipment as specified by the user and/or manufacturer.
So piggy-backing the OSHA standard, the ANSI 5.5.1 standard goes on to say, “if the truck is found to be in need of repair or in any way unsafe, or contributes to an unsafe condition, the matter shall be reported immediately to the user’s designated authority, and the truck shall not be operated until it has been restored to safe operating condition,” and here’s a key point…only authorized personnel should be working on them. So the best option here is to get one of your maintenance employees authorized to make these repairs, or as many companies do, contract with a local equipment company or mechanic shop that assumes the responsibility for keeping these machines working safely. It’s important to have a reputable system like this because what can often happen, is employees, with the best intentions, start adding parts or modifying the equipment in a way that doesn’t specifically meet the manufacturers recommendations. This leads me to the next two standards I wanna highlight. 1910.178(q)(5) states that “All parts of any such industrial truck requiring replacement shall be replaced only by parts equivalent as to safety with those used in the original design.” Second, 1910.178(q)(6) states, “Industrial trucks shall not be altered so that the relative positions of the various parts are different from what they were when originally received from the manufacturer, nor shall they be altered either by the addition of extra parts not provided by the manufacturer or by the elimination of any parts, except as provided in paragraph (q)(12) of this section. Additional counterweighting of fork trucks shall not be done unless approved by the truck manufacturer.” Now, quickly, (q)(12) of the standard that was just referenced is basically talking about forklifts being converted from gasoline to liquified petroleum gas. So what we will often find are repairs or modifications made to forklifts not intended to be made by the manufacturer. And when OSHA sees these modifications made, without engineered or manufacturer approval, they will cite you for these changes. And quickly, if modifications are made, the ANSI standard states in section 6.2.16 that “Modifications and additions that affect capacity and safe truck operation shall not be performed without manufacturer’s prior written approval.” And it goes on to say that if these changes are made, and I quote, “Capacity, operation, and maintenance instruction plates, tags, or labels shall be changed accordingly.” This is an element that gets left out often, so keep that in mind. You always have to communicate new changes to the operators so all capacities and capabilities are accounted for. I will be getting into some detailed examples of these types of items during our final week of the forklift emphasis, so be sure to check that out. There are several specifics I want to show you, so, I’ll be reviewing pictures of citable items we find during our inspections and explain why they would be considered non-compliant. Check that out in a couple weeks.
But getting back to maintenance, one of the main focuses of the operator’s responsibilities in the ANSI standard is on the actual forks of the forklift. I’m not gonna get into the details of each item, but the items they want you to check are:
- Surface Cracks
- Straightness of Blade and Shank
- Fork Angle (Upper Face of Blade to Load of the Shank)
- Difference in Height of Fork Tips
- Positioning Lock (Where Originally Provided
- Overal Wear (specifically the fork and blade shank, and the fork hooks and where they were originally provided)
- Legibility of Marking (When Originally Provided)
There are a lot of specifics in each of these items and I do encourage you to purchase the most updated ANSI 2018 standard for $35 on the ANSI website which is webstore.ansi.org. In this document, they take you through everything you need to know in much greater depth than I’m able to give in this video. And if you create a program that follows very closely to these standards, you should have no citations pop up as a result of your forklift use. But that said, one of the common questions I want to answer before we end this video is, “do I have to write out a daily inspection checklist for each shift and for each operator?” The technical answer is no, you do not have to. However, this is where it always gets tricky. If OSHA can’t draw a clear line to your inspection process, how can they confirm you have any type of maintenance program is in place? It’s the old saying, “if it ain’t written, it ain’t real.” So we do encourage you to have some sort of digital or written system in place that logs these routine inspections. You’ll also want to keep track of all maintenance records you’ve had on your equipment so it’s clear you’re doing everything you can to keep these steel beasts from creating a greater hazard when they’re not functioning properly.
Look, this isn’t a full picture of all maintenance requirements and standards, but I really hope it gives you some solid information to build a foundation from and start to evaluate how strong your forklift maintenance program is. Are you winging it each day, or are you going through these daily and pre-shift requirements on inspection? Do you have an authorized mechanic that you work with either in-house or subbed out, or are you making patches as you go that ultimately change the overall design, capacity, and make-up of the machine? These are only a few questions you need to answer on this topic. If you have any questions on this material, please reach out to your SSG safety consultant, reach out to us in general at email@example.com, call us at 417-823-SAFE, or you can reach out to your digital safety consultant on the Safety Consulting NOW platform. We’re doing great things here at SSG and we’re happy to have you on this journey with us. For Summit Safety Group and Safety Consulting NOW, I’m Jake Woolfenden and I’ll see you next week where we’re gonna dive into some really important points on pedestrian safety as it relates to your forklift use. I’ll see you in the next one.