Analysis of the accidents in the Ministry’s 1996 study revealed a wide variety of immediate causes (collisions, shifting loads, tip-overs), but generally the same root cause: the lack of an effective safety program. Workers were poorly trained; supervision was inadequate; and the work and workplace were not organized with safety in mind. The result was unsafe work practices that made an accident almost inevitable. The development and implementation of a program to address these problems is an obvious first step towards improving powered-lift-truck safety.
While it may be tempting to see truck operators as responsible for accidents and thus better training for them as the way to safe lift truck operations, it is important to recognize that training, although essential, will not be enough to eliminate accidents. To be most effective, operator training should be part of a larger comprehensive powered-lift-truck safety program. This program should include the following elements:
- hazard identification
- training (of both truck operators and those working near lift trucks)
- operating procedures
- maintenance and repair procedures
- facility design
- lift truck selection criteria.
Although the employer is responsible for implementation of the program, it will likely be more effective if all the workplace parties are involved in its development. The joint health and safety committee or health and safety representative, where there is one, along with supervisors and workers should all be involved not only in the development of rules and procedures to prevent injuries, but in identifying the causes of accidents and “near misses”, and the monitoring of lift-truck-safety improvements.
Clause 25(2)(d) of the Occupational Health and Safety Act (OHSA) requires an employer to “acquaint a worker or a person in authority over a worker with any hazard in the work… .” This means that the employer at a workplace where there is a powered lift truck must identify all hazards associated with the truck as it used in the workplace. In practical terms, the following measures and procedures should be carried out:
- Identify the ways in which a worker who operates or works around a powered lift truck could be harmed or injured, taking into consideration the equipment that will be used, the jobs to be done and the workplace environment.
- Prepare a written report that mentions all the potential sources of harm or injury identified in step one above. This report can be used to inform workers about the hazards in their work (as required by clause 25(2)(d) of the OHSA).
- Periodically review the hazard assessment, in case there is a significant change in how the work is carried out, and make appropriate changes to the written report if necessary.
Both workers and supervisors should be involved in the hazard identification process. It should include a review of information provided by the lift truck’s manufacturer, an analysis of work processes and a consideration of accident and injury data. If there is a concern that the workplace does not have sufficient expertise, advice should be sought from the relevant safe workplace association or other safety specialists.
Clause 25(2)(a) of the OHSA places an obligation on an employer to “provide information, instruction and supervision to a worker to protect the health or safety of the worker”. Regulation 851 is more specific and states that a lifting device is only to be operated by a competent person. “Competent person” is defined by the OHSA as someone who:
- is qualified because of his knowledge, training, and experience to organize the work and its performance,
- is familiar with the provisions of this Act and the regulations that apply to the work, and
- has knowledge of any potential or actual danger to health or safety in the workplace.
An employer has a clear duty to establish the competence of the worker who is to operate a powered lift truck, either through training or in some other way. What this entails in practice is explained in Section 4 of this Guideline. Through training an operator should learn: the fundamentals of powered lift trucks, how environmental conditions can affect lift-truck performance, basic lift-truck operating skills, and the rules and practices for safe lift-truck operation. The training should include practice sessions, under the supervision of a qualified trainer, on load handling, maneuvering, travelling, stopping, and starting. Appendix III is an outline of the knowledge and skills (in terms of learning outcomes) that a truck operator should acquire through a successful training program. The Canadian Standards Association also has a training standard (Industrial Lift Truck Operator Training B335-94, [updated to B335-04]), which may be useful in designing or evaluating training programs. (View CSA standards)
In addition to ensuring that the operator of a powered lift truck is appropriately trained, an employer has a responsibility to those whose work in the vicinity of a lift truck may place them at risk. The following measures are suggested:
- For each potential source of harm or injury noted in the hazard identification (above), prepare written rules and procedures for preventing accidents and injuries.
- Ensure that all supervisors and workers who work around lift trucks have been informed of the hazards, instructed in the rules and procedures to avoid harm, and know where the written rules and procedures are located.
- inform supervisors and workers of any revisions to the rules and procedures arising from changes in the work.
Clause 25(2)(c) of the OHSA states that an employer must appoint a competent person as a supervisor. For powered lift truck operations, this means someone who, through training and experience, knows the hazards associated with: the type of lift truck being used, the loads being handled and the environment in which the truck will be operated. A competent supervisor must also be able to identify unsafe acts and conditions and implement corrective measures. Employers, for their part, should encourage supervisors to be vigilant in identifying hazardous situations and correcting them immediately when they are detected.
As a minimum, employers should ensure that the following existing regulatory requirements are complied with:
- no part of a load must pass over any worker;
- a lift truck left unattended must be immobilized and secured against accidental movement and forks, buckets or other attachments must be in the lowered position or firmly supported;
- no load may exceed the maximum rated load and loads must be handled in accordance with the height and weight restrictions on the vehicle’s load chart;
- when a load is in the raised position, the controls must be attended by an operator;
- if an operator does not have a clear view, a signaller who has been instructed in a code of signals for managing traffic in the workplace must be used;
- loads must be carried as close to the ground or floor as the situation permits;
- loads that may tip or fall and endanger a worker must be secured;
- where a lift truck is required to enter or exit a vehicle to load or unload, that vehicle must be immobilized and secured against accidental movement;
- a lift truck must not be used to support, raise or lower a worker on a construction site and must only be so used in an industrial establishment if the work is carried out in accordance with Regulation 851 (Section 52);
- barriers, warning signs, designated walkways or other safeguards must be provided where pedestrians are exposed to the risk of collision.
In addition to the safe operating procedures above, which apply to all workplaces, a second set of rules and safe operating procedures should be developed and implemented to address hazards that are specific to the workplace where the lift truck is to be used.
The operating procedures should include a truck inspection to be carried out at the beginning of the truck operator’s shift. A checklist, to facilitate this pre-shift inspection, should be developed. It should cover fork condition and wear; tire condition and pressure; fluid and fuel levels; battery condition and electrolyte levels; steering, brake, and limit switch operation; and cleanliness. The operator should also examine the chains and mast; check for damage or leaks; and inspect the condition of the lift mechanism. Any defects should be reported to the operator’s supervisor.
Maintenance and Repair Procedures
The OHSA, in clause 25(1)(b), places a general duty on employers to ensure that equipment is maintained in good condition. When the equipment is a lifting device, clause 51(1)(a) of Regulation 851 states that it must be constructed and equipped in a way to adequately ensure the safety of all workers; clause 51(1)(b) deals with its lifting capacity. The only way to ensure these requirements are being met is through a periodic inspection and, where necessary, repair and maintenance of the equipment (powered lift truck). The repair and maintenance should focus on worker safety, not just for the truck’s load-handling characteristics, but for all aspects of the truck’s operations. The points that should be covered in a regular powered-lift-truck inspection are listed in Appendix IV. Repair and maintenance are more fully discussed in Section 5 of this Guideline.
Poor workplace design can contribute to accidents and injuries. Employers should ensure that the following measures are taken as a minimum:
- Overhead and side clearances (at loading docks, through doorways and in rooms) are adequate to permit the safe operation of the lift truck.
- Floors, aisles and passageways are kept clear and free of hazards.
- The workplace is adequately ventilated to prevent the accumulation of vapours from the refueling and operation of lift trucks.
Lift Truck Selection Criteria
It is important to develop criteria for the selection of trucks for use in a particular workplace. Different trucks are designed and manufactured to operate in different work environments and the hazards associated with the use of a specific powered lift truck will depend on its type, make, and model. Steps must therefore be taken to ensure that the fire hazard designation, carrying capacity, reach capabilities and the features of the lift truck selected to do a job are suitable for the types of loads to be handled, the terrain over which loads will be carried, the atmospheric conditions in the workplace and the design of the workplace. Gas-, petrol- or diesel-powered lift trucks should not be used where explosive concentrations of combustible dusts, flammable gases or flammable vapours may be present or in areas where exhaust gases may accumulate creating a hazard of carbon monoxide poisoning, for example.
To protect operators and other workers, every lift truck should have clearly displayed information showing the maximum rated load and the variation of the rated safe load capacity with the reach of the equipment. If a truck has been modified, the information should be revised to reflect new load ratings. Every truck should also be equipped with the following:
- a suitable screen, guard, grill or other structure to protect the operator from falling or intruding materials (which may be mandatory under clause 54(1)(b) of Regulation 851; see Appendix I);
- warning devices and lights that are appropriate for the work environment; and
- a seat belt or other restraining device that is likely to contribute to the safety of the operator, if it is feasible.