Most construction contractors are aware that OSHA has prioritized the enforcement of standards covering powered industrial truck safety. Thus far in 2014, OSHA has issued more than 3,340 citations for violations of its powered industrial trucks standards, which comes in at number six on the top 10 list of most frequently cited OSHA standards for the year.
The number of citations issued for violations of OSHA’s powered industrial truck standards is up in 2014 in comparison to previous years. For example, in 2004 and 2009, OSHA issued 3,149 and 2,993 citations, respectively, for violations of its powered industrial truck standards. The top five forklift citations issued by OSHA this year are based on the failure to:
- ensure operator competency;
- certify operator training and evaluation;
- provide refresher training and evaluation;
- examine forklifts before placing them in service; and
- take damaged forklifts out of service.
OSHA’s prioritization of enforcing powered industrial truck standards seems to be justified based on National Institute for Occupational Safety and Health statistics, which show that forklifts strike pedestrians daily, causing 20,000 injuries and 100 deaths annually with costs estimated to exceed $100 million. Additionally, statistics show that more than 11 percent of forklifts in the United States will be involved in an accident each year and that 90 percent of all forklifts will be involved in some type of accident during their useful life, which is assumed to be eight years.
What can construction contractors do to prevent forklift hazards, incidents and OSHA citations for violation of powered industrial truck standards and, more importantly, to minimize employee injuries and deaths relating to powered industrial truck use in the workplace?
First, contractors should establish a training program that covers:
- forklift operating instructions, warnings and precautions for the type of forklift the employee will be authorized to operate;
- the differences between the operation of forklifts, automobiles and trucks;
- forklift controls and instrumentation;
- engine or motor operation;
- steering and maneuvering;
- restrictions on visibility and blind spots;
- load capacity and stability;
- how loads affect forklift operation;
- moving loads;
- driving on inclines;
- reasons forklifts tip over;
- fueling or charging batteries;
- inspection and maintenance requirements;
- seat beat use;
- forklift use around pedestrians;
- use of forklift;
- loading trailers and railcars;
- loading and unloading high storage shelves; and
- the “dos and don’ts” of forklift operation, such as no passengers, no speeding, driving with forks lowered, parking with forks lowered to the floor and not leaving forklifts loaded and unattended.
The training program also should cover workplace-specific topics, including likely surface conditions; composition of likely loads and stability; load manipulation; likely pedestrian traffic; restricted areas and narrow aisles; hazardous locations where the forklift will operate; ramps and sloped surfaces; and unique potentially hazardous workplace conditions.
Second, the employer must certify that each and every operator has been trained and evaluated. The certification should include the name of the operator, date of training, date of evaluation and names of the person or persons performing the training and evaluations. OSHA requires training and evaluations to be conducted by individuals who have the knowledge, training and experience to train powered industrial truck operators.
Third, the employer should retrain and evaluate operators when they have been observed operating a vehicle in an unsafe manner, involved in an accident or near-miss incident, received an evaluation revealing that the operator is not operating the vehicle safely, assigned to drive a different type of powered industrial truck, or conditions in the workplace change in a manner that could affect the safe operation of a forklift. At least once every three years, operators should be evaluated to test their knowledge and skills have been retained.
Fourth, construction contractors should ensure that all forklifts are examined at least daily before being used, or after each shift if used on a round-the-clock basis. Operators should be given a checklist to ensure inspections are thorough. Supervisors should review inspection checklists to verify the powered industrial truck has been examined and no issues exist that could affect the safe operation of the vehicle. Any forklift that is damaged, defective or otherwise unsafe must be removed from service. The inspection checklists should be retained to show OSHA that required examinations have been timely performed.
Lastly, the employer should conduct periodic audits of its powered industrial truck policies and procedures to ensure compliance with OSHA standards. An annual review is recommended because many things can change in the workplace that could negatively impact the safe operation of forklifts. Audits should not only cover operator training, evaluation and competence and vehicle inspection, but also the supervision of operators and discipline.
Ensuring a safe and healthy workplace for employees requires continuous effort and focus. Developing policies and procedures covering powered industrial truck operation will help construction contractors achieve this goal and to prevent forklift accidents, incidents and OSHA citations.