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.

June 16, 1995

Mr. Michael D. Zoll, CSP
Manager of Safety
Alcan Aluminum Corporation
P.O. Box 6977
Cleveland, Ohio 44101-1977

Dear Mr. Zoll:

This is in response to your January 18, 1994 letter to Mr. Roger Clark requesting a compliance determination from the Occupational Safety and Health Administration (OSHA) as to what type of powered industrial truck can be used in an aluminum powder production building where dust levels may be in an explosive concentration. I apologize for the delay in responding to your inquiry.

Please be advised that 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 II, Group E, Division 1 location, and Section 1910.178(c)(2)(ii)(a) prohibits the use of power-operated industrial trucks in atmospheres containing hazardous concentrations of metal dust, including aluminum, magnesium, and their commercial alloys, or other metals of similarly hazardous characteristics.

Although not adopted by OSHA, later versions of NFPA No. 505 Summary Tables on Use of Powered Industrial Trucks, indicate the type of truck that may be used with the approval of the authority having jurisdiction in a Class II, Group E, Division 1 location. As an authority having jurisdiction OSHA will accept the use of a powered industrial truck that is listed or approved as safe for use in a designated location by an OSHA accepted Nationally Recognized Testing Laboratory, using nationally recognized testing standards. Also, approved trucks must bear a label indicating approval by the testing laboratory.

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