On Safety

On Safety: What does OSHA consider a powered industrial truck?

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One of the common questions we receive from NSC-ORCHSE members is: “Just what all does OSHA include as a powered industrial truck?”

More specifically, many of the questions are further asking whether a golf cart used to transport people within a facility is considered a PIT. (More on this later.)

Unfortunately, OSHA has been somewhat vague in describing what it considers a PIT. The PIT standard for construction (1910.178(a)) states:

“This section contains safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. This section does not apply to compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling.”

Under 1910.178(b), OSHA goes on to designate and describe different classes of PITs as follows:

Designations. For the purpose of this standard there are 11 different designations of industrial trucks or tractors as follows: D, DS, DY, E, ES, EE, EX, G, GS, LP and LPS.” (See 1910.178(b)(1) through 1910.178(b)(12))

On the one hand, it’s pretty clear the standard applies to fork trucks, tractors, platform lift trucks, and motorized hand trucks. But just what does the agency include under the category of “other specialized industrial trucks”?

OSHA has developed a document that lists seven classes of PITs. It’s the only document besides the standard that OSHA, when asked, could point to. The seven classes are:

  1. Electric motor rider trucks (your classic electric forklift)
  2. Electric motor narrow aisle trucks (warehouse material movers)
  3. Electric motor hand trucks or hand rider trucks
  4. Internal combustion engine trucks (solid/cushion tires)
  5. Internal combustion engine trucks (pneumatic tires)
  6. Electric and internal combustion engine tractors
  7. Rough terrain forklift trucks

OSHA provides illustrations of PITs from each class on its website.

So, what about golf carts or other similar vehicles that are designed to transport people around a facility? Are they PITs? The basic answer is no. ANSI/National Golf Car Manufacturers Association Z130.1-2004 defines a golf car(t) as “a vehicle used to convey a person or persons and equipment to play the game of golf in an area designated as a golf course.” Golf car(t)s are considered by design to be recreational vehicles and are exempt from 1910.178. Again, it’s the design of the vehicle that’s the determining factor of whether it’s considered a PIT, rather than the manner in which it’s used. In other words, if it’s designed to haul and move materials, it’s likely a PIT.

Golf carts are used mostly to move people. But they can be modified to transport materials. OSHA lacks regulations for scooters, golf carts and other types of personal conveyances. These types of equipment aren’t covered under PITs or any other specific standard. OSHA does require and expect they will be used safely and could use the General Duty Clause to hold employers responsible for maintaining a safe workplace. To be on the safe side, if golf carts are used to haul materials, even though they aren’t technically covered by 1910.178, you should consider including them in your PIT program.

There have been a few violations of the General Duty Clause related to golf carts. For example, one General Duty Clause citation in the OSHA database states, “Employees were exposed to the hazard of falling from a moving cart.” The violation focused on the employer not following the manufacturer’s instructions in using the golf carts. But no violation was found related to golf carts being considered covered under 1910.178.

This article represents the views of the authors and should not be construed as a National Safety Council endorsement.

Richard Fairfax (CIH, retired 2017) joined OSHA in January 1978 and retired from the agency in 2013. At OSHA, he was a practicing field industrial hygienist, as well as the deputy director and director of enforcement programs. In 2008, Richard served as acting director of construction and, in 2010, was designated deputy assistant secretary – overseeing all field, enforcement and training operations. From 1993 through 2010, Richard wrote an industrial hygiene column entitled, “OSHA Compliance Issues” for the Journal of Occupational and Environmental Hygiene. He still serves on the Editorial Review Board. Richard now works part time for NSC-ORC HSE.

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