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OSHA 1910.178

Powered industrial truck requirements

Subpart N

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.178(a)(1) — What types of vehicles does the Powered Industrial Truck standard cover and what does it exclude?

The Powered Industrial Truck standard covers fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines, and it excludes compressed-air or nonflammable compressed-gas-operated industrial trucks, farm vehicles, and vehicles intended primarily for earth moving or over-the-road hauling. See 1910.178(a)(1) for the full scope.

Under 1910.178(a)(2) — Do new powered industrial trucks have to meet an ANSI standard and where is that requirement stated?

Yes — all new powered industrial trucks an employer acquires and uses must meet the design and construction requirements in ANSI B56.1-1969 unless they are intended primarily for earth moving or over-the-road hauling. This requirement is stated in 1910.178(a)(2) and is incorporated by reference through 1910.6.

Under 1910.178(a)(3) — Must an "approved" powered industrial truck be marked and what does "approved" mean?

Yes — an approved powered industrial truck must bear a label or identifying mark showing approval by a nationally recognized testing laboratory. An “approved truck” means a truck listed or approved for fire safety purposes by a nationally recognized testing laboratory, as explained in 1910.178(a)(7); see the definition of "listed" in 1910.155(c)(3)(iv)(A) and the definition of a nationally recognized testing laboratory in 1910.7.

Under 1910.178(a)(4) — Can employers modify lift trucks themselves if the modification affects capacity or safe operation?

No — employers or users may not perform modifications or additions that affect capacity or safe operation without the manufacturer's prior written approval, and any capacity or instruction plates, tags, or decals must be changed accordingly. See 1910.178(a)(4).

Under 1910.178(a)(5) — If I add a front-end attachment not installed at the factory, what marking is required?

You must request that the truck be marked to identify the attachment and show the approximate weight of the truck-plus-attachment combination at maximum elevation with the load laterally centered. This marking requirement is in 1910.178(a)(5).

Under 1910.178(a)(6) — What must employers do about nameplates and markings on powered industrial trucks?

Employers must ensure all nameplates and markings are in place and kept legible. The requirement to maintain legible nameplates and markings is stated in 1910.178(a)(6).

Under 1910.178(b) and (b)(1) — What is a "D" designation and how does it differ from "G"?

A "D" designated unit is similar to a "G" unit but is diesel-powered instead of gasoline-powered. The definitions of designations, including 1910.178(b)(1) for D units and 1910.178(b)(8) for G units describe these differences.

Under 1910.178(b)(2) and (b)(3) — What are DS and DY designations and when are they used?

DS units are diesel-powered trucks with extra safeguards for exhaust, fuel, and electrical systems and may be used where a plain D unit is unsuitable; DY units have all DS safeguards and additionally lack electrical equipment (including ignition) and have temperature-limiting features for use in more hazardous atmospheres. See 1910.178(b)(2) and 1910.178(b)(3).

Under 1910.178(b)(4)–(7) — What do the E, ES, EE, and EX designations mean for electrical safeguards?

E-designated units are electrically powered with minimum fire-hazard safeguards; ES units add safeguards to prevent hazardous sparks and limit surface temperatures; EE units enclose motors and electrical equipment completely; EX units are built so electrical fittings and equipment allow use in atmospheres containing flammable vapors or dusts. See 1910.178(b)(4), 1910.178(b)(5), 1910.178(b)(6), and 1910.178(b)(7).

Under 1910.178(b)(10)–(11) — What are LP and LPS designations relative to fuel type and safeguards?

LP units use liquefied petroleum gas (LPG) instead of gasoline; LPS units use LPG and include additional safeguards for exhaust, fuel, and electrical systems for use where LP alone might be unsuitable. See 1910.178(b)(10) and 1910.178(b)(11).

Under 1910.178(b)(12) and (c) — Must an area be classified before choosing the type of industrial truck to use?

Yes — the atmosphere or location must be classified as hazardous or nonhazardous before selecting the type of industrial truck, and the required truck types for classified locations are listed in paragraph (d) and Table N‑1. See 1910.178(b)(12) and 1910.178(c).

Under 1910.178(c)(2)(i) — Are power-operated industrial trucks allowed in atmospheres with hydrogen or acetylene?

No — power-operated industrial trucks must not be used in atmospheres containing hazardous concentrations of acetylene, hydrogen, or other listed highly hazardous gases. This prohibition is in 1910.178(c)(2)(i).

Under 1910.178(c)(2)(ii)(a) — Can trucks be used in atmospheres with metal dust or carbon black dust?

Only approved EX-designated power-operated industrial trucks may be used in atmospheres containing hazardous concentrations of metal dust (like aluminum or magnesium) or carbon black, coal, or coke dust; other trucks are prohibited. See 1910.178(c)(2)(ii)(a).

Under 1910.178(c)(2)(ii)(b) — What electrical component enclosures are required where magnesium or aluminum dust may be present?

In atmospheres where magnesium, aluminum, or aluminum-bronze dust may be present, fuses, switches, motor controllers, and circuit breakers on trucks must have enclosures specifically approved for such locations. This requirement is in 1910.178(c)(2)(ii)(b).

Under 1910.178(c)(2)(iii) — When are only EX-designated trucks allowed because of flammable vapors like gasoline or propane?

Only EX-designated approved power-operated industrial trucks may be used where flammable vapors such as gasoline, propane, or naphtha are present in quantities sufficient to produce explosive or ignitable mixtures, whether continuously, intermittently, or frequently due to normal operations or maintenance. See 1910.178(c)(2)(iii).

Under 1910.178(c)(2)(iv) — When may DY, EE, or EX trucks be used near volatile flammable liquids or gases that are normally confined to closed systems?

DY, EE, or EX designated trucks may be used where hazardous liquids or gases are normally confined in closed containers or systems — provided escape would only occur by rupture or failure — and in locations where positive mechanical ventilation normally prevents hazardous concentrations but could fail; adjacent areas to Class I, Division 1 locations may also permit these trucks if adequate positive-pressure ventilation and safeguards against ventilation failure are provided. See 1910.178(c)(2)(iv).

Under 1910.178(c) and Table N-1 — How do Class and Division classifications affect which trucks you can use?

Class (I, II, III) and Division (1 or 2) classifications identify the type of hazardous atmosphere (flammable gases, combustible dusts, or ignitable fibers) and whether the hazard is likely to be present; Table N‑1 and 1910.178(c) show the minimum truck designations required for each class/division, and employers must choose trucks meeting or exceeding those safeguards.

Under 1910.178(a)(7) and 1910.155(c)(3)(iv)(A) — How is "listed" defined for an "approved truck"?

A truck is considered "listed" or "approved" if it is listed or approved for fire safety purposes for the intended use by a nationally recognized testing laboratory; see the definition in 1910.178(a)(7) and the cross-reference to "listed" in 1910.155(c)(3)(iv)(A).

Under 1910.178(a)(5) and (a)(6) — If I add a non-factory attachment, what else must I do besides marking the truck?

Besides requesting marking that identifies the attachment and shows combined weight at maximum elevation, you must ensure all nameplates and markings remain in place and legible and change capacity, operation, and maintenance instruction plates, tags, or decals as needed to reflect the modification. These obligations are in 1910.178(a)(5) and 1910.178(a)(6).

Under 1910.178(b) — How should an employer decide whether to use a DS, GS, or LPS unit in a given area?

Employers should review the area's hazards and choose a designation that provides the necessary additional safeguards (DS for diesel with extra exhaust/fuel/electrical safeguards; GS for gasoline with added safeguards; LPS for LPG with added safeguards) when a plain D, G, or LP unit would be unsuitable for that location. The designation descriptions are in 1910.178(b), and paragraph (d) and Table N‑1 describe required types for classified locations.

Under 1910.178(c)(2)(iii) — If a repair area occasionally emits gasoline vapors during maintenance, which truck designation is required?

If gasoline vapors may exist continuously, intermittently, or frequently during normal operations, repairs, or maintenance, only approved EX-designated power-operated industrial trucks are permitted in that area. This restriction is stated in 1910.178(c)(2)(iii).

Under 1910.178(c)(2)(iv) — Can EX-designated trucks be used adjacent to Class I, Division 1 locations without extra ventilation?

They may be used adjacent to Class I, Division 1 locations only if hazardous concentrations are prevented by adequate positive-pressure ventilation from a source of clear air and effective safeguards against ventilation failure are provided; otherwise additional protections are required. See 1910.178(c)(2)(iv).

Under 1910.178 — If my warehouse stores pre-charged appliances containing a Category 1 flammable gas, could powered industrial truck operations be affected by PSM requirements (29 CFR 1910.119)?

Yes — storing and moving pre-charged appliances with a Category 1 flammable gas on-site in one location may create a PSM-covered process if the aggregate quantity reaches the PSM threshold, and powered industrial trucks moving those units would be activities within that process. OSHA's PSM interpretation explains storage and on-site movement qualify as a "process" under [29 CFR 1910.119], and you should evaluate PSM applicability in addition to selecting appropriate truck designations per 1910.178. See OSHA's interpretation on PSM flammable gas aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 for more details.

Under 1910.178(b)(7) and (c)(2)(iii) — What practical checks should I perform before operating an EX-designated truck in a hazardous atmosphere?

Ensure the truck is properly listed/approved and that all electrical fittings, motors, and enclosures meet EX specifications, confirm the area classification supports EX usage, and verify ventilation or other safeguards are functioning. The EX definition is in 1910.178(b)(7) and the allowed uses in hazardous vapors are in 1910.178(c)(2)(iii).

Under 1910.178(a)(2) and 1910.6 — If my shop repairs older trucks, do those trucks have to conform to ANSI B56.1-1969?

New trucks acquired and used must meet ANSI B56.1-1969 per [1910.178(a)(2)], but the standard specifies that requirement for new trucks; repairs to older trucks should still maintain safe operation and any modification affecting capacity or safety must follow [1910.178(a)(4)]. See 1910.178(a)(2) and 1910.178(a)(4).

Under 1910.178(b)(8)–(9) — When should I choose a GS unit over a plain G unit for gasoline-powered trucks?

Choose a GS unit (gasoline with safeguards) where extra protection for exhaust, fuel, or electrical systems is needed because the plain G unit's minimum safeguards are not suitable for the location; the GS description is in 1910.178(b)(9) and the G unit description is in 1910.178(b)(8).

Under 1910.178(c) — If my facility has areas with grain dust, what classification and truck designation should I consider?

Grain, flour, and starch dust are examples listed under Class III locations (combustible fibers/flyings) in Table N‑1; you should consult Table N‑1 and 1910.178(c) to select trucks that meet the minimum designation for that class and division, and consider trucks with additional safeguards where dust accumulation or ignition sources may be present.

Under 1910.178(c)(2)(vi): Which types of powered industrial trucks are allowed in atmospheres where combustible dust is or may be continuously, intermittently, or periodically in suspension under normal operating conditions?

Only trucks designated as Type EX are permitted in atmospheres where combustible dust is or may be in suspension under normal operating conditions. See 1910.178(c)(2)(vi) for the requirement and examples of hazardous locations (e.g., grain handling areas, pulverizers, mixers) where EX trucks are required. Employers should evaluate whether the area has dust in quantities sufficient to form ignitable mixtures and select EX‑rated trucks accordingly.

Under 1910.178(c)(2)(vii): What truck types may be used where combustible dust is not normally suspended but dust deposits may be ignited by sparks or arcs from the truck?

Trucks designated as DY, EE, or EX may be used where combustible dust is not normally suspended but dust deposits could be ignited by arcs or sparks from the truck. See 1910.178(c)(2)(vii). Employers must assess the likelihood of dust ignition from truck electrical/mechanical sources and choose trucks with appropriate safeguards (DY, EE, or EX) for those areas.

Under 1910.178(c)(2)(viii) and (ix): What truck types are allowed in locations hazardous because of easily ignitable fibers or flyings, and does the rule allow continued use of some older truck types?

Only trucks designated DY, EE, or EX may be used in areas hazardous because of easily ignitable fibers or flyings when those materials are not likely to be suspended in air; locations where easily ignitable fibers are stored or handled (but not processed) may use DS, DY, ES, EE, EX, GS, or LPS trucks, and previously used Type E trucks may be continued in use. See 1910.178(c)(2)(viii) and 1910.178(c)(2)(ix). Employers should classify the area (processing vs. storage) and select trucks accordingly.

Under 1910.178(c)(2)(v): Which powered industrial trucks may be used in locations used for storage of hazardous liquids in sealed containers or compressed gases in containers?

Approved power‑operated industrial trucks designated as DS, ES, GS, or LPS may be used in locations used for storage of hazardous liquids in sealed containers or liquefied/compressed gases in containers. See 1910.178(c)(2)(v). Employers must consider factors such as the quantity of material that could escape, adequacy of ventilation, area size, and the business’s history of fires/explosions when deciding whether these truck types provide sufficient safeguards.

Under 1910.178(c)(2)(x): What trucks are permitted to operate on piers and wharves handling general cargo?

On piers and wharves handling general cargo you may use any approved power‑operated industrial truck designated Type D, E, G, or LP (or trucks that conform to those types). See 1910.178(c)(2)(x). Employers should ensure the chosen truck types meet the operational and environmental conditions present on the pier or wharf.

Under 1910.178(c)(2)(xi) and (xii): When can any Type D, E, G, or LP truck be used in storage warehouses or general industrial/commercial properties?

If storage warehouses or general industrial/commercial properties are not classified as hazardous, any approved powered industrial truck designated Type D, E, G, or LP (or trucks that conform to those types) may be used. If those locations are classified as hazardous, only the specific truck types listed for that hazardous classification may be used. See 1910.178(c)(2)(xi) and 1910.178(c)(2)(xii). Employers must assess whether a location is hazardous and then restrict truck types accordingly.

Under 1910.178(d) and (q): Can a gasoline‑approved truck converted to LPG be used where G, GS, LP, or LPS trucks are specified?

Yes—power‑operated industrial trucks that were originally approved for gasoline and converted to liquefied petroleum gas (LPG) in accordance with paragraph (q) may be used where G, GS, LP, and LPS designated trucks are specified. See 1910.178(d) and follow the conversion requirements in paragraph (q) of the standard. Ensure conversions strictly meet the requirements in (q) before using the converted trucks in those locations.

Under 1910.178(e)(1) and (e)(2): When must powered industrial trucks have overhead guards and load backrest extensions?

High‑lift rider trucks must be fitted with an overhead guard unless operating conditions do not permit, and fork trucks must be equipped with a vertical load backrest extension when the load type presents a hazard. See 1910.178(e)(1) and 1910.178(e)(2). Employers should evaluate loads and operating conditions and install these safety guards whenever required by the standard.

Under 1910.178(f): How must fuel for powered industrial trucks be stored and handled?

Storage and handling of liquid fuels (gasoline and diesel) must follow the NFPA Flammable and Combustible Liquids Code (NFPA No. 30), and storage and handling of liquefied petroleum gas (LPG) must follow NFPA No. 58, as incorporated by reference in accordance with 1910.6. See 1910.178(f)(1), 1910.178(f)(2), and 1910.6. Follow those NFPA codes and any local fire code requirements for safe fuel handling and storage.

Under 1910.178(g): What are the basic requirements for locations where batteries are charged or changed?

Battery charging installations must be located in designated areas that provide flushing/neutralizing for spilled electrolyte, fire protection, protection of charging equipment from truck damage, and adequate ventilation to disperse fumes. See 1910.178(g)(1) and 1910.178(g)(2). Employers must also provide handling equipment (e.g., conveyors or hoists), ensure batteries are positioned and secured after reinstalling, and provide equipment such as carboy tilters or siphons for electrolyte handling as required by the standard.

Under 1910.178(g)(7)–(12) and (i)(1): What safe practices must be followed when charging batteries and operating powered industrial trucks to control battery hazards and fumes?

When charging batteries, always pour acid into water (never water into acid), position and brake trucks before changing/charging batteries, ensure vent caps function and compartments are open to dissipate heat, prohibit smoking in charging areas, prevent open flames/sparks/arcs, and keep metallic tools away from uncovered batteries. See 1910.178(g)(7), 1910.178(g)(8), 1910.178(g)(9), 1910.178(g)(10), 1910.178(g)(11), and 1910.178(g)(12). Also, control of noxious gases and fumes requires that carbon monoxide concentrations produced by truck operations not exceed the levels specified in 1910.1000, so provide adequate ventilation and monitor CO where appropriate.

Under 1910.178(h)(2): What lighting is required for truck operating areas with low general lighting?

If general lighting in the operating area is less than 2 lumens per square foot, the truck must be equipped with auxiliary directional lighting. See 1910.178(h)(2). Employers should measure lighting levels and provide auxiliary lights on trucks when general illumination is insufficient for safe operation.

Under 1910.178(k)(1)–(4): What protections are required when loading or unloading highway trucks and railroad cars with powered industrial trucks?

Highway truck brakes must be set and wheel chocks placed under the rear wheels while they are boarded with powered industrial trucks; wheel stops or other positive protection must prevent railroad cars from moving during loading/unloading; fixed jacks may be needed to support semitrailers not coupled to a tractor; and positive protection must prevent railroad cars from moving while dockboards/bridge plates are in position. See 1910.178(k)(1), 1910.178(k)(2), 1910.178(k)(3), and 1910.178(k)(4). Implement these positive protections before truck operations begin.

Under 1910.178(l)(1) and (l)(1)(i): What must employers ensure about powered industrial truck operators before they are allowed to operate a truck?

Employers must ensure each powered industrial truck operator is competent to operate safely as demonstrated by successful completion of the training and evaluation specified in paragraph (l). See 1910.178(l)(1) and 1910.178(l)(1)(i). That means providing the required training and an on‑the‑job evaluation to confirm the operator’s competence before permitting independent operation.

Under 1910.178(l)(2)(i)–(iii) and (l)(2)(ii): When may trainees operate trucks, and what must training include and who may conduct it?

Trainees may operate powered industrial trucks only under the direct supervision of qualified trainers and only when such operation does not endanger the trainee or others. See 1910.178(l)(2)(i)(A) and 1910.178(l)(2)(i)(B). Training must combine formal instruction, practical training, and an evaluation of workplace performance per 1910.178(l)(2)(ii), and all training and evaluations must be conducted by persons who have the knowledge, training, and experience to train and evaluate operators as required by 1910.178(l)(2)(iii).

Under 1910.178(l)(3)(i): What truck‑related topics must be included in initial operator training?

Initial operator training must include truck‑related topics such as operating instructions, differences from automobiles, controls and instrumentation, engine/motor operation, steering and maneuvering, visibility limitations, fork/attachment use, vehicle capacity and stability, required inspections and maintenance tasks, battery charging/refueling, operating limitations, and any instructions in the operator’s manual. See 1910.178(l)(3)(i) and its subparts (A)–(M) for the full list. Tailor training to the types of trucks and workplace conditions applicable to each operator.

Under 1910.178(g)(4): What equipment is required to handle batteries when changing or charging them?

A conveyor, overhead hoist, or equivalent material handling equipment must be provided for handling batteries during changing or charging. See 1910.178(g)(4). Use appropriate lifting/handling equipment to prevent manual handling injuries and to safely move heavy batteries in the charging area.

Under 1910.178(l)(4)(iii) (Refresher training and evaluation), how often must an employer evaluate each powered industrial truck operator's performance?

Employers must evaluate each powered industrial truck operator's performance at least once every three years. This requirement is stated in 1910.178(l)(4)(iii).

  • The purpose of the periodic evaluation is to confirm the operator still has the skills and judgment to operate the truck safely.
  • If an evaluation shows unsafe operation, the operator must receive refresher training as described in 1910.178(l)(4)(ii).
  • Document the evaluation date and results as part of the certification record required by 1910.178(l)(6).

Under 1910.178(l)(4)(ii) (Refresher training), what specific events require an employer to provide refresher training to a powered industrial truck operator?

Refresher training is required whenever any of the listed conditions in 1910.178(l)(4)(ii) occur. Those conditions are:

  • The operator has been observed operating the vehicle in an unsafe manner (1910.178(l)(4)(ii)(A)).

  • The operator has been involved in an accident or a near-miss incident (1910.178(l)(4)(ii)(B)).

  • An evaluation shows the operator is not operating the truck safely (1910.178(l)(4)(ii)(C)).

  • The operator is assigned to drive a different type of truck (1910.178(l)(4)(ii)(D)).

  • A workplace condition changes in a way that could affect safe operation (1910.178(l)(4)(ii)(E)).

  • Provide refresher training that covers the relevant topics in 1910.178(l)(3), and evaluate the operator to confirm competence after the training.

Under 1910.178(l)(6) (Certification), what information must an employer include in the operator training and evaluation certification?

The employer must certify that each operator has been trained and evaluated and include the operator's name, date of training, date of evaluation, and the identity of the person(s) who performed the training or evaluation. This certification requirement is in 1910.178(l)(6).

  • The certification can be a record kept by the employer and should be available for review.
  • Keep the certification details updated whenever refresher training or a new evaluation is completed to show continued compliance with 1910.178(l).
  • Appendix A to 1910.178 offers non-mandatory guidance to help implement the training program (1910.178(l)(8)).

Under 1910.178(m)(5) and related paragraphs, what must an operator do when leaving a powered industrial truck unattended and how is "unattended" defined?

When leaving a powered industrial truck unattended, the operator must fully lower the load engaging means, neutralize the controls, shut off power, and set the brakes; wheels must be blocked if the truck is parked on an incline. This is required by 1910.178(m)(5)(i) and related text in paragraph (m)(5).

  • "Unattended" means the operator is 25 feet or more away from the vehicle which remains in the operator's view, or whenever the operator leaves the vehicle and it is not in the operator's view (1910.178(m)(5)(ii)).
  • If the operator dismounts but stays within 25 feet and still has the truck in view, the load engaging means must still be fully lowered, controls neutralized, and brakes set (1910.178(m)(5)(iii)).

Following these steps prevents unintended movement and reduces the risk of injury or property damage.

Under 1910.178(o)(1) and 1910.178(o)(2) (Loading), can powered industrial trucks handle off-center loads or loads beyond the truck's rated capacity?

No; only stable or safely arranged loads within the truck's rated capacity may be handled, and caution must be used with off-center loads. This is required by 1910.178(o)(1) and 1910.178(o)(2).

  • Do not exceed the rated capacity plate of the truck; handling heavier loads can cause tipping or loss of control.
  • For long, high, or multiple-tiered loads that affect capacity or stability, make required adjustments before moving the load (1910.178(o)(3)).
  • Place the load-engaging means as far under the load as possible and tilt the mast back to stabilize the load (1910.178(o)(5)).

If you cannot center or stabilize an off-center load safely, do not attempt to handle it until you can do so within safe limits.

Under 1910.178(q)(6) and 1910.178(q)(7) (Maintenance of industrial trucks), are employers allowed to alter trucks or use non-equivalent replacement parts, and what inspection frequency is required before placing trucks in service?

Employers must not alter industrial trucks so that part positions differ from the original design nor add or eliminate parts unless allowed by [1910.178(q)(12)]; replacement parts must be equivalent as to safety. This is stated in 1910.178(q)(6) and 1910.178(q)(5). Additionally, trucks in need of repair must be removed from service and repaired by authorized personnel per 1910.178(q)(1).

  • All replacement parts must be "equivalent as to safety" to the original design parts (1910.178(q)(5)).
  • Industrial trucks must be examined before being placed in service and not placed in service if any condition adversely affecting safety is found; this examination must be made at least daily and after each shift when used around the clock (1910.178(q)(7)).
  • Repairs to electrical systems require battery disconnection first (1910.178(q)(4)).

Following these rules helps maintain safe operation and prevents hazards caused by improper modifications or missed defects.