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| Technical Information Bulletin |
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U.S. Department of Labor
Occupational Safety and Health Administration |
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Inspection of Suspension-Type Highway Trailers Prior to Loading and Unloading with Powered Industrial Trucks
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| TIB 01-12-21 |
This TIB is not a new standard or regulation
and it creates no new legal obligations. It is
advisory in nature, informational in content,
and is intended to assist employers in providing
a safe and healthful workplace.
For a more detailed description of the nature
and effect of Technical Information Bulletins,
see the Important Information box at the end of
this bulletin. |
Purpose
The purpose of this Technical Information Bulletin
is:
- To alert employers and employees regarding the
need to inspect suspension-type highway trailers
to ensure that the trailers will support powered
industrial trucks during loading and unloading operations;
and
- To provide a list of inspection check points for
employers and employees to use in order to determine
whether it is safe to use powered industrial
trucks for loading and unloading such trailers.
Technical Information
There are three trailer designs of primary concern:
(1) the fiberglass-reinforced panel; (2) the sheet
and post; and (3) the plate trailer.
These trailers are designed and manufactured
in a manner similar to a suspension bridge with the
weight of the floor and the load supported by the
walls, which hang from the roof of the trailer. The
roof of the trailer, in turn, is supported at the four
corners of the trailer. The undercarriage of the trailer
consists of a series of parallel rails that run laterally
across the trailer. The rails are attached to the remainder
of the trailer by a group of four to six rivets
at each end of the rail.
These trailer designs were developed to
decrease the weight of the trailer, thereby increasing
the allowable weight of the load that the trailer
can carry. The trailers can be identified by the
absence of an I beam running fore and aft under
the full length of the trailer floors.
Recommendations
Suspension-type trailers should be inspected
before they are loaded or unloaded with a powered
industrial truck. Any of the following types of damage
to the trailer should be identified and documented. A determination should be made whether
the trailer can or cannot be loaded or unloaded safely
prior to using a powered industrial truck. In the event
that the trailer cannot be loaded or unloaded safely
with a powered industrial truck, an alternative means
of loading or unloading must be used. If the integrity
of the trailer cannot be assured and no other reasonable
means exists to complete the operation, the
trailer should be taken out of service.
Inspection Check Points
- Examine the rear impact guard (the ICC bar).
Damage to this guard may indicate the presence
of other damage to the trailer, thereby decreasing
the trailer’s ability to support the weight of the
load and the powered industrial truck used to load
or unload the trailer. Also, when a trailer restraint
is used, a damaged ICC bar may prevent the trailer
restraint from effectively engaging, thus permitting
the trailer to roll away from the dock.
- Examine the front landing gear of the trailer. Damage
to this part of the trailer could cause the trailer
landing gear and the front of the trailer to collapse
when the weight of the powered industrial truck
is added to the weight of the trailer and the load
being supported by the front landing gear.
- Examine the cross members of the undercarriage
for missing pieces, excessive corrosion, or permanent
deformation. For example, deformation
of the cross members caused by missing rivets at
the ends of the cross members can indicate damage
to the trailer floor. In such cases, the trailer
may not support the weight of a powered industrial
truck.
- Examine the exterior sides of the trailer for tears or cuts of the skin that
exceed 21 inches or that would affect more than one trailer side post.
- Look for missing rivets, particularly near the bottom
of the trailer. Damaged or missing rivets may
indicate that the ability of the undercarriage to
support the weight of the load and the powered
industrial truck used to move the load has been
compromised.
- Look at the rear doors of the trailer. Damage to
the rear doors of the trailer may indicate that the
trailer was struck in the rear, thereby possibly causing
other damage to the trailer and possibly creating
a hazard when opening and closing doors.
- Look at the hinges that support the rear doors.
Damage to these hinges could indicate damage to
the floor of the trailer or a shifting of the load during
transit. Damage to the hinges could include
broken or missing rivets, damage to other means
of hinge attachment (e.g., welds), broken hinges,
or missing hinge pins. Damage of this nature may
compromise the ability of the trailer to support
the weight of the powered industrial truck.
- Examine the interior walls of the trailer for breaks,
tears or other damage, particularly within two feet
of the floor of the trailer. Tears or cuts in more
than one post could adversely affect the ability of
the trailer to support the weight of the load and
the powered industrial truck being used to move
the load. On sheet and post trailers, vertical posts
(most commonly on 16" - 24" centers) should not
be severed. A vertical post that is severed presents
a hazard.
- Look at the roof of the trailer. Damage to the roof
of the trailer may indicate the mishandling of the
load when the trailer was being loaded and unloaded.
Such mishandling could produce other
structural damage to the trailer that may be visually
apparent. Damage to the roof structure of the
trailer could allow trailer walls to fold in or out
resulting in a floor collapse.
- Examine the floor of the trailer; look for imperfections
or abnormalities, including an excessively
wavy appearance of the laminated floor, delamination
of the floor, cracks, and/or missing pieces
of flooring. When unloading the trailer, the powered
industrial truck operator should continually
check the condition of the newly exposed portion
of the floor as the unloading proceeds. The powered
industrial truck operator also should check
for water stains on the floor, which may indicate
that the floor has been damaged by water [see 29
CFR 1910.178 (m)(7)].
The existence of any one, or even several,
of the above listed deficiencies does not necessarily
render the trailer unsafe to enter with a powered industrial
truck. However, such deficiencies are indications
of possible serious damage, and the employer
will need to exercise professional judgment to determine
whether it is safe to use a powered industrial
truck for loading and unloading the trailer.
Important Information on the
Nature and Effect of Technical
Information Bulletins
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OSHA’s Directorate of Science, Technology and Medicine (DSTM) issues Technical Information Bulletins
(TIBs) to provide information about occupational
hazards and /or to provide information about
noteworthy, innovative, or specialized procedures,
practices and research that relate to occupational
safety and health. DSTM selects topics for TIBs
from recognized scientific, industrial hygiene,
labor, industry, engineering, and/or medical
sources.
The Occupational Safety and Health Act
requires employers to comply with hazard-specific
safety and health standards. In addition, employers
must provide their employees with a workplace
free from recognized hazards likely to cause death
or serious physical harm under Section 5(a)(1), the
General Duty Clause of the Act. Employers can be
cited for violating the General Duty Clause if there
is a recognized hazard and they do not take appropriate
steps to prevent or abate the hazard. However,
the failure to implement TIB recommendations
is not, in itself, a violation of the General
Duty Clause. Citations can only be based on
standards, regulations, and the General Duty
Clause.
Further information about this bulletin may
be obtained by contacting OSHA’s Directorate of Science, Technology and Medicince at 202-693-2300 |
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