From: Gary Jones (firstname.lastname@example.org )
Date: Sun, 7 Dec 2003 20:19:10
FYI - From safteng.net
Have you modified your forklift?
An OSHRC decision analysis Item 6(a) alleges a violation of 29 C.F.R. 1910.178(a)(4), which applies to powered industrial trucks and provides as follows: Modifications and additions which affect 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.
The record shows that a XXXX forklift truck at the facility with a capacity of 5500 pounds was being used with 10-foot steel fork extensions that had been made at the facility; the original forks were 4 feet long, and the extensions, which fit over the original forks and were removable, were used to move pallets with items on them. The record further shows, and the company admits, that it did not obtain the manufacturer's approval to use the extensions.
The Compliance Safety & Health Officer (CSHO) testified that the operator, showed him the pallets and foam panels he had recently moved with the extensions; the pallets were 10 feet long and weighed 921 pounds, and the panels were 14 feet long and 8 feet, 4 inches wide. The CSHO said the load center of the original forks was 2 feet, while the load center of the extensions was 5 feet, or 1 foot beyond the original forks. He also said this change decreased the truck's capacity and made it a hazard because it would not handle the way it was designed to handle; more of the weight of the foam panels would have been distributed beyond the 2-foot load center, creating the potential for the truck to tip over or lose its load, either of which could have caused serious injury.
The Secretary also presented a manager with XYZ Handling Systems, in regard to this item. He said this truck normally has 42 or 48-inch forks, that its load center is 24 inches, and that it usually lifts 48-inch pallets. He also said putting 10-foot extensions on a truck with 48-inch forks is prohibited. First, extensions have no capacity beyond the forks, and extensions that are too long result in tremendous stress on the forks, which can actually break during the lift. Second, putting 10-foot extensions on the truck in question would make the load center 60 inches, which would reduce the truck's capacity to around 2500 pounds. Third, the extensions would cause the center of gravity to be "way off" and the truck would be unstable.
He stated that a truck trying to lift over its capacity simply might not be able to, or the back wheels might just raise up a little. However, the truck might be able to lift the load but could lose it if the truck attempted to lift it higher or went over uneven ground, and the load could fall on someone; the truck could also tip over, causing injury to the driver. He further stated that changing the capacity without changing the information plate was also a hazard, as an operator unfamiliar with the truck would not know its true capacity.
Based on the foregoing, the company violated the cited standard. It is clear the company did not obtain the manufacturer's approval before using the extensions and that the truck's capacity plate was not changed. It is also clear that the extensions and the failure to change the plate represented a hazard. This conclusion is supported by the testimony of the XZY Handling Systems Manager, which was credible and convincing. It is also supported by the testimony of the operator, who believed the truck's capacity to be 5500 pounds when the extensions were used.
A conclusion that the extensions were a hazard is even supported by the company. Although the CSHO testified about the extensions and pallets being used to move foam panels, the company testified they were also used to move wire. The pallets weigh 921 pounds, and, if loaded with wire, they could easily weigh over 2500 pounds. Item 6(a) is affirmed as a serious violation.