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.
OSHA's Directorate of Technical Support (DTS) 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. DTS 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 Technical Support and Emergency Management (formerly Directorate of Technical Support) at 202-693-2300.
The purpose of this Technical Information Bulletin is:
The Directorate of Safety Standards Programs brought to the attention of the Directorate of Technical Support the fact that workers engaged in the loading or unloading of suspension-type highway trailers may be at an increased risk of injury due to the inability of damaged trailers to support the weight of the powered industrial truck used to load or un- load the trailer. These trailer designs present hazards not encountered with trailers of older, traditional designs. OSHA has received several reports of trailer collapse accidents in situations in which the employees attempted to enter a trailer and to load or unload that trailer with a powered industrial truck.
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.
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.
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.
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