1910 & 178

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Everyone doing well? I certainly hope so! And I appreciate you checking in with us here at Warehouse and Operations as a Career. I’m Marty and I’m happy to report I’m well as well! I want to dive right in today with a quick story. 2 weeks ago, I sat in on a PIT class or powered industrial truck class. A gentleman was in attendance, very knowledgeable, turned out to be very experienced with operating an electric platform rider jack, he’d been a high productivity order selector for a number of years. He of course sailed through the classroom part of the standard. We all went out to the equipment, it wasn’t a big class, I think there were 5 others, and everybody lined up. It was hot! We’re in Texas, in August, it’s just hot. I was standing over by him and we struck up a conversation while the instructors were giving the others their observations 1 at a time. He was not happy about having to wait his turn. He told me that he did not understand why he was forced to take this class and that waiting to jump on a pallet jack just to be observed was, well, he didn’t say silly but I got the just of it. He felt like his recruiter had verified his references and knew what he could do on a jack. I told him I was certain he’d been certified or licensed before right. He said no, that he’d never sat through any class like he’d just sat through. I asked him if he’d ever heard of OSHA? He said of course. I asked him what it meant to him. He just shrugged his shoulders. I pointed out that he’d just sat through a class that referenced 29cfr1910.178, Powered Industrial Trucks like 10 times. He said yea, and I took notes, I wanted to go check it out. The class did teach me a lot about the center of gravity, weight management on the lifts and especially about going up and down ramps. I’ve been doing it wrong about half the time. Well, it was his turn on the palletjack, so our conversation was over, and, by the way, he was as good, confident and as safe an operator as he’d professed to be! I never expected to hear from him again but to my amazement. I’m getting way ahead of myself here, I’ll circle back around with running into him again in a minute.

Let’s talk about the OSHA standard 29CFR for a bit. CFR stands for Code of Federal Regulations, there’s 50 of them. I’m adding the OSHA.gov link in the show notes. My hope is that after today you’ll just have to go check them out for yourself! https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.178

I found a simple to understand Title or Code chart on Wikipedia, I’ll add it here too. https://en.wikipedia.org/wiki/Code_of_Federal_Regulations It shows us that title 29 is Labor.

Maybe we should back up a little bit. In 1970, President Richard Nixon, along with the Congress of course, created the Occupational Safety and Health Organization. An agency dedicated to the idea that us workers should never have to choose between our lives and a safe work environment. By the way this was a bipartisan effort, everyone did use to get along! That was probably wrong to say right?

Anyway, so now let’s look at 1910, kind of the meat of the standard for me! 1910 is the part number – titled occupational safety and health standards. Now 1910 starts out with 1910 Sub Part A, and it runs all the way to Subpart Z and then starts picking up Appendixes and classifications, stuff way above my head so check it out yourself. I wanted to talk about just one or two real quick. 1910.a .1 is purpose and scope. 1910.a.5 Applicability of standards. 1910 subpart D is walking-working surfaces. 1910 subpart H .111 is storing and handling anhydrous ammonia. And then we’ll jump all the way down to subpart N .178 – Powered Industrial Trucks.

So, we’re at Title 29 of the Code of Federal Regulations part number 1910 part number title occupational safety and health standards, subpart N Materials Handling and Storage, and at standards number 1910.178 title powered industrial trucks better known as 29cfr1910.178!

Lets look at a few of them:

1910.178(a)

General requirements.

1910.178(a)(1)

This section contains safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. This section does not apply to compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling.

1910.178(a)(2)

All new powered industrial trucks acquired and used by an employer shall meet the design and construction requirements for powered industrial trucks established in the “American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969”, which is incorporated by reference as specified in §1910.6, except for vehicles intended primarily for earth moving or over-the-road hauling.

1910.178(a)(6)

The user shall see that all nameplates and markings are in place and are maintained in a legible condition.

1910.178(b)

Designations. For the purpose of this standard there are eleven different designations of industrial trucks or tractors as follows: D, DS, DY, E, ES, EE, EX, G, GS, LP, and LPS.

1910.178(e)

Safety guards.

1910.178(e)(1)

High Lift Rider trucks shall be fitted with an overhead guard manufactured in accordance with paragraph (a)(2) of this section, unless operating conditions do not permit.

1910.178(g)

Changing and charging storage batteries.

1910.178(g)(1)

Battery charging installations shall be located in areas designated for that purpose.

1910.178(g)(2)

Facilities shall be provided for flushing and neutralizing spilled electrolyte, for fire protection, for protecting charging apparatus from damage by trucks, and for adequate ventilation for dispersal of fumes from gassing batteries.

1910.178(g)(3)

[Reserved]

1910.178(g)(4)

A conveyor, overhead hoist, or equivalent material handling equipment shall be provided for handling batteries.

1910.178(g)(5)

Reinstalled batteries shall be properly positioned and secured in the truck.

Lighting for operating areas.

1910.178(h)(1)

[Reserved]

1910.178(h)(2)

Where general lighting is less than 2 lumens per square foot, auxiliary directional lighting shall be provided on the truck.

1910.178(i)

Control of noxious gases and fumes.

1910.178(j)

Dockboards (bridge plates). See subpart D of this part.

1910.178(k)

Trucks and railroad cars.

1910.178(k)(1)

The brakes of highway trucks shall be set and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with powered industrial trucks.

1910.178(k)(2)

Wheel stops or other recognized positive protection shall be provided to prevent railroad cars from moving during loading or unloading operations.

1910.178(k)(3)

Fixed jacks may be necessary to support a semitrailer and prevent upending during the loading or unloading when the trailer is not coupled to a tractor.

1910.178(k)(4)

Positive protection shall be provided to prevent railroad cars from being moved while dockboards or bridge plates are in position.

1910.178(l)

Operator training.

1910.178(l)(1)

Safe operation.

1910.178(l)(1)(i)

The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l).

1910.178(l)(1)(ii)

Prior to permitting an employee to operate a powered industrial truck (except for training purposes), the employer shall ensure that each operator has successfully completed the training required by this paragraph (l), except as permitted by paragraph (l)(5).

1910.178(l)(2)

Training program implementation.

1910.178(l)(2)(i)

Trainees may operate a powered industrial truck only:

1910.178(l)(2)(i)(A)

Under the direct supervision of persons who have the knowledge, training, and experience to train operators and evaluate their competence; and

1910.178(l)(2)(i)(B)

Where such operation does not endanger the trainee or other employees.

1910.178(l)(2)(ii)

Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator’s performance in the workplace.

1910.178(l)(2)(iii)

All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.

1910.178(l)(3)

Training program content. Powered industrial truck operators shall receive initial training in the following topics, except in topics which the employer can demonstrate are not applicable to safe operation of the truck in the employer’s workplace.

1910.178(l)(3)(i)

Truck-related topics:

1910.178(l)(3)(i)(A)

Operating instructions, warnings, and precautions for the types of truck the operator will be authorized to operate;

1910.178(l)(3)(i)(B)

Differences between the truck and the automobile;

1910.178(l)(3)(i)(C)

Truck controls and instrumentation: where they are located, what they do, and how they work;

1910.178(l)(3)(i)(D)

Engine or motor operation;

1910.178(l)(3)(i)(E)

Steering and maneuvering;

1910.178(l)(3)(i)(F)

Visibility (including restrictions due to loading);

1910.178(l)(3)(i)(G)

Fork and attachment adaptation, operation, and use limitations;

1910.178(l)(3)(i)(H)

Vehicle capacity;

1910.178(l)(3)(i)(I)

Vehicle stability;

1910.178(l)(3)(i)(J)

Any vehicle inspection and maintenance that the operator will be required to perform;

1910.178(l)(3)(i)(K)

Refueling and/or charging and recharging of batteries;

1910.178(l)(3)(i)(L)

Operating limitations;

1910.178(l)(3)(i)(M)

Any other operating instructions, warnings, or precautions listed in the operator’s manual for the types of vehicle that the employee is being trained to operate.

1910.178(l)(3)(ii)

Workplace-related topics:

1910.178(l)(3)(ii)(A)

Surface conditions where the vehicle will be operated;

1910.178(l)(3)(ii)(B)

Composition of loads to be carried and load stability;

1910.178(l)(3)(ii)(C)

Load manipulation, stacking, and unstacking;

1910.178(l)(3)(ii)(D)

Pedestrian traffic in areas where the vehicle will be operated;

1910.178(l)(3)(ii)(E)

Narrow aisles and other restricted places where the vehicle will be operated;

1910.178(l)(3)(ii)(F)

Hazardous (classified) locations where the vehicle will be operated;

1910.178(l)(3)(ii)(G)

Ramps and other sloped surfaces that could affect the vehicle’s stability;

1910.178(l)(3)(ii)(H)

Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust;

1910.178(l)(3)(ii)(I)

Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation.

1910.178(l)(3)(iii)

The requirements of this section.

1910.178(l)(4)

Refresher training and evaluation.

1910.178(l)(4)(i)

Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely.

1910.178(l)(4)(ii)

Refresher training in relevant topics shall be provided to the operator when:

1910.178(l)(4)(ii)(A)

The operator has been observed to operate the vehicle in an unsafe manner;

1910.178(l)(4)(ii)(B)

The operator has been involved in an accident or near-miss incident;

1910.178(l)(4)(ii)(C)

The operator has received an evaluation that reveals that the operator is not operating the truck safely;

1910.178(l)(4)(ii)(D)

The operator is assigned to drive a different type of truck; or

1910.178(l)(4)(ii)(E)

A condition in the workplace changes in a manner that could affect safe operation of the truck.

1910.178(l)(4)(iii)

An evaluation of each powered industrial truck operator’s performance shall be conducted at least once every three years.

1910.178(l)(5)

Avoidance of duplicative training. If an operator has previously received training in a topic specified in paragraph (l)(3) of this section, and such training is appropriate to the truck and working conditions encountered, additional training in that topic is not required if the operator has been evaluated and found competent to operate the truck safely.

1910.178(l)(6)

Certification. The employer shall certify that each operator has been trained and evaluated as required by this paragraph (l). The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation.

I may have went a little long there. But this is really interesting when you start reading through it. Of course it is not necessary to know the entire standard word for word. As equipment operators we’re going to learn a lot of it, but I bet we’ll be a much better employee if we practice a bit more of it.

I hope you’ll at least pull it up and check it out. I’ve added the OSHA website page mark right here in the show notes. Go to warehouseandoperationsasacareer.com and click the link. Easy peasy. I’ll reach out and get us a bona fide safety person on the show to really explain it all to us but here’s the little bit I know. I like it anyway!

So, I told you I saw that student again. To my amazement he stopped back buy to see us the following week. He wanted to let me know he had gotten the job and was loving it. He said I had sparked his interest in the whole 29CFR1910.178 thing and he wanted me to know that he had read the entire thing. He fists bumped me ( a covid 19 thing) and left.

Until next week, please be Safe, check out our safety standards. Our family needs us to know them!

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