Removal of forklift safety devices
I was recently asked about backup alarms. The question was “Do we have to use them and can they be moved to a new location on the lift?” The question got me thinking and I decided to check my thoughts with some other sources. What I found out complicates matters involving this type of issue for end users and dealers.
1) OSHA states in a letter of interpretation that backup alarms and strobes are not required equipment on forklifts. This applies to forklifts in general industry; construction related forklifts have different requirements that may require them.
2) OSHA 29CFR1910.178(q)(6) states: “Industrial trucks shall not be altered so that the relative positions of the various parts are different from what they were when originally received from the manufacturer, nor shall they be altered either by the addition of extra parts not provided by the manufacturer or by the elimination of any parts.”
During my investigation, I spoke with one major OEM forklift manufacturer and a member of the ASME b56.1 committee on powered industrial trucks. Everyone agreed on one thing, OSHA does not require forklifts used in general industry to have backup alarms or strobes per the OSHA letter of interpretation. From there it gets a little fuzzy. If the manufacturer of the lift considers the backup alarm or strobe as optional or an accessory then they can be removed or moved without the manufacturer’s consent, but if the manufacturer considers them as standard equipment, then they can’t be removed or moved without the consent of the manufacturer. By the way, several major brands now consider them as standard equipment.
It seems strange to me that an end user is not allowed to remove something that OSHA does not require in the first place, but this is in fact the case with items considered as standard equipment. As a side note, all safety devices which are present on your forklifts must be operational. If I had a dollar for every alarm, strobe or blue light that I see out of service on forklifts every day I would be a very rich man! Many end users seem to take this issue very lightly and continue to allow lifts to remain in service with safety devices clearly not operating, this is to their own peril if there is an accident.
A minor OSHA fine is not the real concern here. Think for a moment about the huge lawsuit which might arise if a lawyer learns his client was injured or killed by a forklift with missing or altered safety warning devices!
In summary, before you remove, alter or move something on a forklift, either as an end user or a dealer, you should check with the factory first to be sure they are in agreement.
Written by Brian Colburn of Forklift Training Systems, a leading provider of forklift safety training and materials. Look for Forklift Training Systems at www.forklifttrainingsystems.com. Email email@example.com with questions or call 614-583-5749.