Scaffold platforms on rough-terrain forklift forks

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 27, 1992

MEMORANDUM FOR: JOHN PHILLIPS
Regional Administrator
LEO CAREY, Director Office of Field
Programs

FROM: PATRICIA K. CLARK, Director Directorate of Compliance
Programs

SUBJECT: Work Platforms on Rough Terrain Fork Trucks.

This is in response to your February 25 memorandum in which you request specific guidance regarding citation policy for work platforms attached to the forks of rough terrain fork lifts. I apologize for the delay in responding to your request.

Your comments on the language that should be included in the revised scaffold rules have been forwarded to the Office of Construction and Civil Engineering Safety Standards for evaluation. However, it is important to note that whether or not OSHA should prohibit the use of fork-lifts to support scaffold platforms, was raised as Issue Number 3 in the November 25, 1986 Notice of Proposed Rulemaking (51 FR 42680, 42697). The public record indicates that such platforms should be allowed provided guardrails, proper platform strength, stability, and attachment are provided. The final rule, however, is still in draft form.

In the meantime, appropriate citations could include:

§1926.451(a)(3) Supervision by competent person

.451(a)(4) Guardrails (no body belt/harness systems). Note: The 4 to 10 foot portion of this paragraph is intended to apply to such make-shift scaffolds (see 1986 NPRM at 42689).

.451(a)(10) Minimum grade lumber

.451(a)(12) Platform shall be secured from movement (although a pallet cannot move sideways, it can slide forward).

Paragraph 5(a)(1) could be cited when appropriate, referencing ANSI A10.8-1988 paragraph 4.31 (maximum 4 to 1 height to base width ratio without tying or guying or outriggers).

If you have any questions, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at FTS 523-8136.