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 20, 1976

Mr. Walter Chapman, Director,
Marion Power Shovel Company, Inc.
617 W. Center Street
Post Office Box 505
Marion, Ohio 43302

RE: Your letter dated September 22, 1976 - OSHA 1910.178

Dear Mr. Chapman:

Your letter refers to our standard 1910.178(a)(2). This paragraph deals with design and construction requirements for powered industrial trucks, not with operator qualifications.

Our standards contain only minor reference to operator qualifications. In [1910.178(l)(1)(i)] you will read, "Only trained and authorized operators shall be permitted to operate a powered industrial truck."      (Correction 02/16/99) ["The employer shall ensure that each power 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)."]      No mention is made of vision requirements. The ANSI Standard B56.1-1969 in Section 6 reads, "Operators of powered industrial trucks shall be physically qualified. An examination should be made on an annual basis and include such things as field of vision, hearing, depth perception, and reaction timing."

[This document was edited on 12/22/00 to strike information that no longer reflects current OSHA policy.]

While OSHA did not adopt this requirement, it merits your consideration. People with only one eye do not generally have good depth perception; this could be a most important and critical matter in some industrial operations. You, as an employer, must determine if full vision is mandatory in your operations. We suggest you consult with your company's medical department.

In closing we remind you that the standard does not apply to vehicles intended primarily for earth moving or over-the-road hauling. Please contact us if we can be of further service.

Very truly yours,

Nicholas DiArchangel
Acting Regional Administrator
for Occupational Safety and Health

cc: Wash., D.C.