Archive Notice - OSHA Archive

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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

November 12, 1976

MEMORANDUM FOR:   Area Directors

Subject:          Powered Industrial Trucks - Clarification

A question has been raised regarding applicability of 29 CFR 1910.178(n)(7)(ii) to trucks engaged in loading or unloading trailers, since it does not seem to be compatible with 1910.178(n)(7)(ii).

Paragraph (i) is mandatory, and requires loaded trucks ascending or descending grader greater than 10% to be driven with the load upgrade. To do otherwise can be dangerous.

Paragraph (ii) is advisory, and is intended for operations other than direct loading and unloading of trailers. It should be considered a general recommendation for improved vision and comfort of the operator.

Regional Administrator