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 7, 2000

Mr. Timothy J. Rubush
Plant Engineering Supervisor
3M
Plant Engineering Services
Industrial Vehicle Service Center
900 Dayton Avenue
Ames, Iowa 50010

Dear Mr. Rubush:

Thank you for your January 10, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You have questions regarding the Powered Industrial Truck Standard, 29 CFR 1910.178. We appreciate the opportunity to provide you with clarification on this matter.

You specifically have a question regarding 29 CFR 1910.178(q)(7). It requires that powered industrial trucks be examined at least daily prior to being placed in service. The standard does not require documentation of a powered industrial truck examination. Therefore, it would be at the employer's discretion to determine the duration of powered industrial truck examination record retention. The employer must not place a powered industrial truck in service if the examination shows any condition which adversely affects the safety of the vehicle. Defects found during an examination must be immediately reported and corrected.

Thank you for you interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at
http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement at 202-693-1850].

Sincerely,


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]