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Label Forklifts for Attachments before you're on a first
name basis with an OSHA Compliance Officer...
...or you see yourself on 60
Minutes.
The same forklift must be rated for different capacities
depending upon mast height and type of attachment. Extending
weight out on the forks can decrease load stability.
We
recently met an OSHA Compliance Officer who asked how we
handle labeling lift trucks for use with our
drum handling
attachments. He liked Morse's online forms for lost load
calculations. However, that left the question of actually
labeling the forklift unanswered.
He has seen cases
when used trucks are rented or purchased, with no authorized
dealer involved. You may not be able to get the forklift
manufacturer to cooperate. He said an alternative is "...if
the employer has... written approval from a qualified
Registered Professional Engineer..."
The relevant wording from an OSHA letter of
interpretation is: "Written approval from the manufacturer
of a powered industrial truck is required for modifications
and/or additions if the modifications and/or additions
affect the capacity and safe operation of the truck.
However, please be aware that OSHA would consider the lack
of manufacturers approval to be a de minimis violation [so
minor as to be disregarded] if the employer has obtained
written approval from a qualified Registered Professional
Engineer after receiving no response or a negative response
from the powered industrial truck manufacturer.
If
the manufacturer's response was negative, then the engineer,
prior to granting approval for the modification or addition,
would need to perform a safety analysis and address all
safety and/or structural issues contained in the
manufacturers disapproval...."
OSHA's
Standard Interpretation
states in part: "Modifications and additions which
affect the capacity and safe operation shall not be
performed by the customer or user without manufacturers
prior written approval. Capacity, operation, and maintenance
instruction plates, tags, or decals shall be changed
accordingly."
Please
refer to
center of gravity dimensions for
calculating lost load when using your forklift with a
Morse drum handling attachment.
The full text of OSHA's powered industrial truck
standard 29 CFR 1910.178 is on their website:
www.osha.gov
Oct. 26, 2005 |
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