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.

May 24, 1995

Mr. E. C. Arms, Jr.
Regulatory Specialist
Westvaco Box 70848
Charleston Heights, SC 29415-0848

Dear Mr. Arms:

Your letter dated January 31, 1994 to the Occupational Safety and Health Administration (OSHA) Dallas Regional Office requesting clarification of the use of powered industrial trucks in Class I, Division 2, Group C locations was transferred to the Directorate of Compliance Programs for response. I apologize for the delay in responding to your inquiry.

29 CFR 1910.178(c), Designated locations, was adopted from NFPA No. 505-1969, Powered Industrial Trucks. Table N-1 of 1910.178, Summary Table on Use of Industrial Trucks in Various Locations, does not list any trucks authorized for use in a Class I, Group C, Division 1 or 2 location. Therefore, your interpretation of Table N-1 of 1910.178 is correct.

Table 1-5 of NFPA No. 505-1992, Summary Table on Use of Powered Industrial Trucks, also does not list any trucks authorized for use in a Class I, Group C, Division 1 or 2 location. As indicated in your letter, the Class I, Group C, Division 2 location in Table 1-5 has table symbols under trucks designated as Type DS, DY, ES, EE, EX, GS, LPS, and GS/LPS which indicate "Type truck authorized to be determined by the authority having jurisdiction."

Although OSHA has not adopted NFPA No. 505-1992, please be advised that OSHA will accept compliance with Table 1-5 of NFPA No. 505-1992, only when it indicates "Type truck authorized in location described."

Therefore, OSHA will accept the use of powered industrial trucks that indicate "Type of truck authorized" in Table N-1 of 1910.178 and later versions of Summary Tables of NFPA No. 505.

OSHA will accept the use of a powered industrial truck that is listed or approved for fire safety purposes for the intended use by an OSHA accepted Nationally Recognized Testing Laboratory (NRTL), using nationally recognized testing standards. In addition, approved trucks must bear a label indicating approval by the testing laboratory.

Specifically, Section 1910.307(b), Electrical Installations, requires that equipment, wiring methods, and installations of equipment in hazardous (classified) locations shall be intrinsically safe, approved for the hazardous (classified) locations (NEPA 70, the National Electrical Code, lists or defines hazardous gases, vapors, and dusts by "Groups" characterized by their ignitible or combustible properties.), or safe for the hazardous (classified) location (NFPA 70, the National Electrical Code, contains guidelines for determining the type and design of equipment and installations which will meet this requirement).

Section 1910.307 would not apply to sweepers and scrubbers used in nonhazardous (nonclassified) locations.

If we can be of any further assistance, please contact Mr. Wil Epps of my staff at (202) 219-8041.


John B. Miles, Jr.
Directorate of Compliance Programs