Page 41 - Powered Industrial Trucks
P. 41
P3 Safety Solutions, LLC Powered Industrial Trucks - Operators (1910.178)
• Standard Number: 1910.178(q)(7); 1910.178(p)(1); 1910.178(q)(5)
August 13, 2004
Mr. William Overby
2932 Hazel Ave.
Dayton, OH 45420
Dear Mr. Overby:
Thank you for your May 7, 2004 letter to the Department of Labor, Occupational Safety and Health
Administration (OSHA). This letter constitutes OSHA's interpretation only of the requirements herein, and may
not be applicable to any question(s)/scenario not delineated within your original correspondence. You had a
specific questions regarding the sound level of a warning device (horn) located on a forklift. We apologize for
the delay in responding to your request.
Question: When a forklift has a weak sounding horn, what determines whether it should be replaced or not?
Reply: OSHA's standard 29 CFR 1910.178(q)(7) requires that industrial trucks be inspected at least daily and
not be placed into service if the examination shows any condition that may adversely affect the safety of the
industrial truck. Additionally, §1910.178(p)(1) states, "If at any time a powered industrial truck is found to be in
need of repair, defective, or in any way unsafe, the truck shall be taken out of service until it has been restored
to safe operating condition." If the industrial truck is equipped with a horn as its warning device, then OSHA
would consider the truck as being unsafe if the sound level of the horn has deteriorated to a level that
can no longer be heard above the ambient noise in the workplace.
In addition, the employer must meet the requirements in §1910.178(q), Maintenance of industrial trucks.
Specifically, §1910.178(q)(5) states, "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."
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA
requirements are set by statute, standards, and regulations. Our interpretation letters explain these
requirements and how they apply to particular circumstances, but they cannot create additional employer
obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our
enforcement guidance may be affected by changes to OSHA rules. To keep apprised of such developments,
you can 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
41