- 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.
July 28, 1997
Ms. Laura Angelo
1445 Woodson Road
St. Louis, Missouri 63132-2580
Dear Ms. Angelo:
This is in response to your letter of June 27, requesting compliance assistance with the Occupational Safety and Health Administration (OSHA) powered industrial truck standard 29 CFR 1910.178. The questions you asked and the corresponding responses follow.
Question 1: Are seatbelts required to be installed on older lift trucks and if so under what standard and section is this addressed?
Response: OSHA does not require seatbelts to be installed on older powered industrial trucks. OSHA's enforcement policy relative to the use of seat belts on powered industrial trucks is that employers are obligated to require operators of powered industrial trucks which are equipped with seat belts to use the devices. 1910.178 does not address seat belts, therefore OSHA enforces the use of seat belts under Section 5(a)(1) general duty clause of the Occupational Safety and Health Act. Section 5.3.19, ASME B56.1-1993 - Safety Standard for Low Lift and High Lift Trucks, addresses the operator restraint system (seat belt) requirements.
Question 2: If a lift truck has a seatbelt is it required to be worn and if so under what standard and section is this addressed?
Response: See response to question #1.
Question 3: Are backup alarms required to be installed on older lift trucks and if so under what standard and section is this addressed?
Response: OSHA standards do not require backup alarms on lift trucks.
Question 4: Are strobe lights required on lift trucks?
Response: OSHA standards do not require strobe lights on lift trucks.
Question 5: Are head lights required on lift trucks?
Response: OSHA standard 1910.178(h) addresses lighting in operating areas. Controlled lighting of adequate intensity should be provided in operating areas.
Question 6: Are tail/brake lights required on lift trucks?
Response: OSHA standards do not require tail/brake lights on lift trucks.
You may also wish to contact powered industrial truck manufacturers for supplemental information. If we can be of any further assistance, please contact Mr. Wil Epps of my staff at (202)219-8041.
John B. Miles, Jr., Director
Directorate of Compliance Programs