Safety Tidbit #2.27 – Forklift Attachments
On
occasion, while touring job sites, I notice various attachments for use on the
company forklift. I understand the need for them as they extend the use of the
forklift. I have seen attachments for picking up workers to handling long rolls
of product or materials. Usually, I find them tucked back in a corner, but on
occasion, their use is in plain sight while I am there. On examination, the
attachments appear to be well made and sturdy.
Sometimes, they are even powder coated with decals, although most
attachments are homemade contraptions made for a particular application.
When
I ask the employer if forklift manufacturer has approved the attachment for use
with their forklift? Remember the employer is to train the worker on the safe
and proper use of the forklift in accordance with the manufacturer’s
requirements. Unfortunately, the typical responses include “Does it have to
be?” or “We use it infrequently” or “We have not had any problems in the past.”
OSHA’s Powered Industrial Truck standard [1910.178(a)(4)] states:
“Modifications and additions which affect capacity and
safe operation shall not be performed by the customer or user without
manufacturer's prior written approval. Capacity, operation, and maintenance
instruction plates, tags, or decals shall be changed accordingly.”
Furthermore,
OSHA as written several letters of interpretation about this circumstance the
oldest letter is from 1997. You can imagine the reluctance of many forklift
manufacturers to grant authorization to use an attachment on their forklift. I
wish to share the response from the letter’s second question:
“With regard to compliance with 1910.178(a)(4),
employers must seek written approval from powered industrial truck
manufacturers when modifications and additions affect the capacity and safe
operation. However, if no response or a negative response is received from the
manufacturer, OSHA will accept a written approval of the modification/addition
from a Qualified Registered Professional Engineer. A Qualified Registered
Professional Engineer must perform a safety analysis and address any safety
and/or structural issues contained in the manufacturer’s negative response
prior to granting approval. Machine data plates must be changed accordingly.”
Another
subtler point, I had a client with a personnel carrier cage made by the
forklift company. It even had company logo decals on it. However, the rating
for the forklift did not include personnel carrier use. In fact, the forklift
the company had prohibited the specific forklift from personnel carrier use as
was written right in the owner’s manual. Ultimately, if you are going to use an
attachment on your forklift, get approval first.
Hope
this was helpful and thanks for reading my Safety Tidbits ~ Bryan
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