Page 41 - Powered Industrial Trucks
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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








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