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.

November 15, 1993

Mr. Dan Freeman
Safety Consulting & Training, Inc.
#4 Deerwood Drive
Blue Grass, Iowa 52726

Dear Mr. Freeman:

Thank you for inquiries of October 4, requesting clarification of the Occupational Safety and Health Administration (OSHA) standard, 29 CFR 1910.178.

Your specific questions and our responses to them are listed as follows:

  1. When a forklift truck is used for lifting personnel on a secured safety platform with a guardrail to perform work at an elevated position, would an employer have to abide by OSHA standard 29 CFR 1910.67(c)(2)(v) requiring the use of a body belt and lanyard to restrain personnel from climbing or leaning over the guardrail?

    Response: No, the 1910.67(c)(2)(v) standard does not apply to forklift trucks.

  3. In the same situation as described above, would an employer have to abide by OSHA standard 29 CFR 1910.67(c)(2)(ix) requiring that the elevated platform have controls accessible to the personnel located on the platform. If this section would not apply, then what controls would be required?

    Response: No, the 1910.67(c)(2)(ix) standard does not apply to forklift trucks. The enclosed [1910.178(m)(12)] standard requires trucks that are equipped with vertical and horizontal controls elevatable with the lifting carriage of forks for lifting personnel to be provided with a power shut off switch at the platform. If the powered industrial truck is not equipped with controls elevatable with the lifting carriage of forks, a cut-off switch for personnel on the platform is not required.

    [This document was edited on 1/5/2003 to strike information that no longer reflects current OSHA policy.]

  5. When occasionally using forklift trucks to elevate personnel on a secured safety platform, what requirements would an employer be required to follow if 1910.67 does not apply?

    Response: In the situation described the employer must follow the requirements of 1910.178.

  7. If other regulations or referenced material would apply to this situation, would you please forward that information to me.

    Response: Another reference is ANSI B56.1-1969. Due to copyright restrictions we are unable to send you a copy. The ANSI address and telephone number are as follows:
American National Standards Institution
1430 Broadway
New York, New York 10018
Telephone Number (212) 642-4900

Enclosed are letters of interpretation for 1910.178(m)(12)(ii), 1910.178(a)(4), 1910.178(a)(1) and 1910.178(g)(2).

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.


Roger A. Clark, Director

[Corrected 1/5/03. On June 2, 2003 a technical amendment was published in the
Federal Register that removed all of paragraph 1910.178(m)(12), including its subordinate paragraphs 1910.178(m)(12)(i) through 1910.178(m)(12)(iii).]