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. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 22, 1999

Mr. Bob Mundson
Mitsubishi Caterpillar Forklift America
2011 W. Sam Houston Pkwy N.
Houston, TX 77095

Dear Mr. Mundson:

Thank you for your September 1, 1999 letter to the Office of General Industry Compliance Assistance (GICA). You have questions regarding fork inspection requirements for powered industrial trucks. These questions are being answered in terms of the employer being the user of the powered industrial truck not the manufacturer. 29 CFR 1910.178(a)(2) requires that powered industrial trucks meet the design and construction requirements established in ANSI B56.1 - 1969 American National Standard for Powered Industrial Trucks, Part II which is incorporated by reference.

Question 1. Must the fork inspectors be certified by a metallurgy board like the American Society for Non-Destructive Testing? If so, do they need to be re-certified on a periodic basis?

Reply. There is currently no specific OSHA requirement for fork inspectors to be certified. However, under 29 CFR 1910.178(l) Powered Industrial Truck Operator Training, the employer would need to provide the operator with training on truck-related topics such as, but not limited to: fork and attachment adaptation, operation, and use limitations; and any vehicle inspection and maintenance that the operator will be required to perform.

Question 2. Does OSHA require the fork inspection procedure as defined by ANSI B56.1?

Reply. 1910.178(q)(7) does have a general requirement that all powered industrial trucks be examined before being placed in service. This examination is required daily or after each shift if the trucks are used on a round-the-clock basis. ANSI B56.1 - 1993 Safety Standard for Low and High Lift Trucks has specific procedures for inspecting and repairing of forks in service on forklift trucks at section 6.2.8. These specific inspection procedures have not been adopted by OSHA. However, an employer does have the responsibility to determine that forks are properly inspected. The failure to properly inspect forks on powered industrial trucks may in some circumstances be a recognized hazard and therefore warrant the use of the general duty clause in enforcement.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may 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 Compliance Assistance at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs