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.

February 9, 1996

Mr. Mark A. Krause, CSP, ARM
Loss Control Consultant
CNA Insurance Companies
P.O. Box 24164
Louisville, Kentucky 40224

Dear Mr. Krause:

Thank you for your letter dated January 19, addressed to Mr. Joe Dear, Assistant Secretary for the Occupational Safety and Health Administration (OSHA), requesting a clarification of 29 CFR 1910.178(k)(1). Your letter was transferred to the Directorate of compliance Programs for response.

1910.178(k)(1) states "The brakes of highway trucks shall be set and wheel chocks placed under the rear wheels to prevent the trucks from rolling while they are boarded with powered industrial trucks." With regard to whether the words "rear wheels" in the standard are intended to mean that both sides of the rear axle must be chocked, please be advised that compliance with this standard can be met when sufficient chocks are provided under the rear trailer wheels that prevent unintentional movement of highway trucks and trailers while being boarded with powered industrial trucks.

In addition, please find an enclosed copy of OSHA Instruction STD 1-11.7 which addresses the use of mechanical means to secure trucks or trailers to a loading dock.

If we can be of any further assistance, please contact [the Office of General Industry Compliance Assistance at (202) 693-1850].

Sincerely,

John B. Miles, Jr.
Director
Directorate of Compliance Programs