Page 26 - Powered Industrial Trucks

November 4, 2004

Mr. William Overby
2932 Hazel Ave.
Dayton, OH 45420

Dear Mr. Overby:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA). The Directorate of
Enforcement Programs (DEP) received your letter on May 10. This letter constitutes OSHA's interpretation only
of the requirements discussed and may not be applicable to any question or scenario not delineated within
your original correspondence. You had specific concerns about 29 CFR 1910.178(n)(8) and 29 CFR
1910.178(n)(15).

Background: 29 CFR 1910.178(n)(8), requires that "[u]nder all travel conditions the truck shall be operated at
a speed that will permit it to be brought to a stop in a safe manner."

29 CFR 1910.178(n)(15), requires that "[w]hile negotiating turns, speed shall be reduced to a safe level by
means of turning the hand steering wheel in a smooth, sweeping motion. Except when maneuvering at a very
low speed, the hand steering wheel shall be turned at a moderate, even rate."

Question: What does OSHA consider a "safe speed" to be for the operation of a powered industrial truck?

Reply: OSHA does not have specific speed limits set for the safe operation of a powered industrial
truck. However, in determining what is a safe speed, OSHA would take a variety of factors into consideration.
These factors include, but are not limited to, the type of truck itself, 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 are not available, OSHA would consider the totality of the
circumstances surrounding the operation of the powered industrial truck in determining whether safe travel
speeds are practiced at a workplace. For additional assistance in determining safe travel speeds, an employer
could look to consensus standards such as ASME B56.1-2000 Safety Standard For Low Lift and High Lift Trucks.
For example, paragraph 4.3.2 of ASME B56.1 contains a Stopping Distance formula which may be useful in
determining approximate theoretical stopping distances where certain variables are known. This information,
along with other factors, can then be used to calculate a maximum safe speed.

Thank you for your interest in occupational safety and health. We hope you find this information helpful.
Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification,
or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish
to verify that the guidance provided herein remains current, you may consult OSHA's website at
http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General
Industry Enforcement at (202) 693-1850.

Sincerely,

Richard E. Fairfax
Director Directorate of Enforcement Programs

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