- Standard Number:
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 http://www.osha.gov.
April 27, 1992
MEMORANDUM FOR: JOHN PHILLIPS Regional Administrator LEO CAREY, Director Office of Field Programs FROM: PATRICIA K. CLARK, Director Directorate of Compliance Programs SUBJECT: Work Platforms on Rough Terrain Fork Trucks.
This is in response to your February 25 memorandum in which you request specific guidance regarding citation policy for work platforms attached to the forks of rough terrain fork lifts. I apologize for the delay in responding to your request.
Your comments on the language that should be included in the revised scaffold rules have been forwarded to the Office of Construction and Civil Engineering Safety Standards for evaluation. However, it is important to note that whether or not OSHA should prohibit the use of fork-lifts to support scaffold platforms, was raised as Issue Number 3 in the November 25, 1986 Notice of Proposed Rulemaking (51 FR 42680, 42697). The public record indicates that such platforms should be allowed provided guardrails, proper platform strength, stability, and attachment are provided. The final rule, however, is still in draft form.
In the meantime, appropriate citations could include:
§1926.451(a)(3) Supervision by competent person
.451(a)(4) Guardrails (no body belt/harness systems). Note: The 4 to 10 foot portion of this paragraph is intended to apply to such make-shift scaffolds (see 1986 NPRM at 42689).
.451(a)(10) Minimum grade lumber .451(a)(12) Platform shall be secured from movement (although a pallet cannot move sideways, it can slide forward).
Paragraph 5(a)(1) could be cited when appropriate, referencing ANSI A10.8-1988 paragraph 4.31 (maximum 4 to 1 height to base width ratio without tying or guying or outriggers).
If you have any questions, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at FTS 523-8136.