Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

October 2, 1980

Arrow Star Inc.
620 William St.
Lynbrook, New York 11563


Your recent catalog 82-5 advertises fork extensions which you offer for use on fork lift trucks. In our opinion, your ad misleads prospective customers. Fork extensions directly effect the stability, capacity, and safety of operation of fork lift trucks.

The Occupational Safety and Health Standard, 29 CFR 1910.178(a)(4) states, in part:

Modifications and additions which effect capacity and safety of operation shall not be performed by the customer or user without manufacturers prior written approval.

This approval is required to assure that the design criteria for the safe use of fork lift trucks will not be exceeded. Therefore, users of fork extensions who have not received manufacturers written approval for such modifications are in direct violation of the OSHA regulatory standard. It is recommended that your catalog reflect this requirement.


John K. Barto, Chief
Division of Occupational
   Safety Programming