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Earlier battery-restraint interpretation revised in 2003

Summary A truck-equipment company asked how reinstalled forklift batteries must be secured. OSHA’s 2000 answer said batteries must be restrained both horizontally and vertically. OSHA revised that answer in March 2003 to say the restraint must work horizontally and/or vertically as the manufacturer intended; use the later answer.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
2000-09-11-0
Date issued
September 11, 2000
Status
Superseded
OSHA revised this September 11, 2000 answer in its March 18, 2003 letter, which says the restraint must work horizontally and/or vertically as the manufacturer intended. OSHA also labels the old letter archival.
Status last verified October 9, 2026

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This document has been superseded. Ezel checks what federal law requires today, under current federal labor law, and answers your situation with citations.

This document has been superseded
OSHA revised this September 11, 2000 answer in its March 18, 2003 letter, which says the restraint must work horizontally and/or vertically as the manufacturer intended. OSHA also labels the old letter archival. It no longer reflects the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

September 11, 2000

Kenneth D. Green

Material Handling of Tennessee, Inc.

[Recipient address omitted]

Dear Mr. Green:

Thank you for your January 6, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You have questions regarding OSHA's requirements for vertical battery restraints in electric powered industrial trucks. Your several questions can be answered as follows:

In General Industry, safety requirements for reinstalling batteries in electric powered industrial trucks are found at 29 CFR §1910.178(g)(5). This paragraph requires that "reinstalled batteries shall be properly positioned and secured in the truck [emphasis added]." Accordingly, batteries in all electric powered industrial trucks covered by the standard must be secured in place both horizontally and vertically when the truck is in use.

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, and correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance 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 Compliance Assistance at 202-693-1850.

Sincerely yours,

Richard E. Fairfax, Director

Directorate of Compliance Programs

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