- 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.
November 4, 2004
Mr. William Overby
2932 Hazel Ave.
Dayton, OH 45420
Dear Mr. Overby:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA). The Directorate of Enforcement Programs (DEP) received your letter on May 10. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question or scenario not delineated within your original correspondence. You had specific concerns about 29 CFR 1910.178(n)(8) and 29 CFR 1910.178(n)(15).
Background: 29 CFR 1910.178(n)(8), requires that "[u]nder all travel conditions the truck shall be operated at a speed that will permit it to be brought to a stop in a safe manner."
29 CFR 1910.178(n)(15), requires that "[w]hile negotiating turns, speed shall be reduced to a safe level by means of turning the hand steering wheel in a smooth, sweeping motion. Except when maneuvering at a very low speed, the hand steering wheel shall be turned at a moderate, even rate."
Question: What does OSHA consider a "safe speed" to be for the operation of a powered industrial truck?
Reply: OSHA does not have specific speed limits set for the safe operation of a powered industrial truck. However, in determining what is a safe speed, OSHA would take a variety of factors into consideration. These factors include, but are not limited to, the type of truck itself, the manufacturer's limitations on the truck, the load being carried, adequate stopping distances, operating surface conditions, pedestrian traffic, and other safety issues. While specific speed limits are not available, OSHA would consider the totality of the circumstances surrounding the operation of the powered industrial truck in determining whether safe travel speeds are practiced at a workplace. For additional assistance in determining safe travel speeds, an employer could look to consensus standards such as ASME B56.1-2000 Safety Standard For Low Lift and High Lift Trucks. For example, paragraph 4.3.2 of ASME B56.1 contains a Stopping Distance formula which may be useful in determining approximate theoretical stopping distances where certain variables are known. This information, along with other factors, can then be used to calculate a maximum safe speed.
Thank you for your 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.
Richard E. Fairfax, Director
Directorate of Enforcement Programs