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DISCUSSION FORUMS : Forkliftaction.communicate
Forum: Safety, training & legislation
Discussion:  Forklift Inspections
Number of messages: 22
Page: [1] 2
START MESSAGE:
dee_c
Oklahoma, United States
What is the OSHA standard for (Length of Time) to keep the inspection records for daily inspections sheets? In case of an OSHA Audit, I believe its 1 year, but looking for clarifiaction, my home state is OKLAHOMA.

Thanks in advance

Posted 5 Apr 2012 01:34 AM Reply  Report this message
REPLIES: Sort replies by
TheBirdman
Oklahoma, United States

Wow hey dee c  I'm in OK as well!  I will be interested in the replies as well.  So far no one has asked me that yet but I do a fair amount of Operator Training so I am sure it will come up. If I had my rathers I would do nothing but training and let someone else peddle the forklifts----

Posted 5 Apr 2012 07:31 AM Reply  Report this message
joseph_h
Michigan, United States
U.S. OSHA does not require written documentation for PIT daily inspection activity. A wise employer, however, will document such activity. Any record retention is at the discretion of the employer.

Google: OSHA Interpretation Powered Industrial Truck 02/07/2000

Google: OSHA Interpretation Powered Industrial Truck 07/28/2004

To obtain a complete list of OSHA PIT interpretations:
Google: OSHA Standard Interpretations 1910.178


Modified 5 Apr 2012 11:10 AM
by poster.
Reply  Report this message
TheBirdman
Oklahoma, United States

Cool, thanks Joseph. I had an idea this is how it works, but good advice to keep records just in case.  

Posted 6 Apr 2012 07:20 AM Reply  Report this message
edward_t
South Carolina, United States

it might be worth noting that while there is no OSHA requirement for keeping the record of the inspection, there is a requirement to do the inspection every shift, and you should expect to have to prove that the inspection is done, should/when OSHA decides to inspect the workplace safety.

-------------------------
"it's not rocket surgery"


Posted 6 Apr 2012 08:19 PM Reply  Report this message
Jplayer
North Carolina, United States

even though its true, the OSHA documentation does not specifically say you have to keep the records you do on daily shift inspections, its only common sense that you would keep such records in the case of an incident that required OSHA to get involved.
I'm sure that was an oversight they made when implementing the rules for industrial truck daily shift inspections into thier documentation. EVERY lifttruck training class i've ever seen they tell you to inspect the truck before use and we routinely instruct the customers to do regular daily inspections (before each shift if they run multiple shifts). And in alot of cases provide them with an inspection sheet or an outline of one they can use.
We dont tell them to do this for nothing :o)

Think about it for a second, IF your company had an incident where injury was the case involving an industrial truck and OSHA was called to the scene for investigation... "one" of the many things they will do is ask for the maintenance and inspection records of the lift in question. Also for records of the operators training and work history at that company.

I'm sure there will be a revision in the future that will physically include those terms in the documentation. Theres always some schmuck lawyer somewhere that will find that loophole to help get some weasle out of trouble .... doh!

-------------------------
John Player Jr
_________________
LiftOne, LLC
Charlotte, NC
Email: jplayer@liftone.net


Modified 6 Apr 2012 09:05 PM
by poster.
Reply  Report this message
joseph_h
Michigan, United States
OSHA and common sense is a definite oxymoron. The failure to require documentation is not an oversight. It is a common practice in the majority of the OSHA standards

In accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520), OSHA must request Office of Management and Budget (OMB) approval of the collection of any information required in any safety or health standard. Approval is only granted if it is specific and deemed to be necessary and relevant data.

The OSHA standard states: 1910.178(q)(7) - Industrial trucks shall be examined before being placed in service, and shall not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination shall be made at least daily. Where industrial trucks are used on a round-the-clock basis, they shall be examined after each shift. Defects when found shall be immediately reported and corrected.

The OSHA standard gives no specific information as to what the inspection consists of. Because the standard is vague, OMB cannot grant documentation approval.

OSHA can only enforce regulations as written and presented in the Final Rule of the rule-making process. Any changes (other than typographical errors) require a new rule-making process. This is a long, time consuming, and expensive process.

Employers do not need documentation for OSHA. They need documentation for potential lawsuits, especially third party wrongful death suits. The records that should be kept are those that document that a problem was found and the supporting documentation that shows that the problem was corrected.

A million copies of a daily inspection that are signed off by the operator but likely never really performed are meaningless.


Modified 7 Apr 2012 03:17 PM
by poster.
Reply  Report this message
Jplayer
North Carolina, United States

dee
after all that stuff i posted in my previous post i never really did answer your question and i should apologise for that.

There is no "rule" written about how long to keep the "daily inspection" sheets. If it were my decision i'd keep them indefinatly, but thats just me. :o)

-------------------------
John Player Jr
_________________
LiftOne, LLC
Charlotte, NC
Email: jplayer@liftone.net


Posted 8 Apr 2012 00:44 AM Reply  Report this message
dee_c
Oklahoma, United States
Jplayer, thanks for your responses, they were very helpful, and thanks to everyone that replied, I have been a forklift instructor for 8 years and I have never had this question come up and in our operating enviroment here I thought this is something that would eventually come up so I thought I would seek out the answer ahead of time. I just went through a OSHA audit and inspection and did not ask the inspector the question, but this was something that I wanted clarification on.
Thanks again. Dee C

Posted 10 Apr 2012 09:43 PM Reply  Report this message
calvin_w
Victoria, Australia
Hi everyone
In Australia it is legislated that records must be kept ,once again not sure of the time frame , but data kept on the history of a forklift /orderpicker can only prove beneficial in the long run. We produce a 12 month,  daily safety check & maintenance logbook for this purpose, we have sold them in the US , Britian  Canada , Australia and New Zealand, just google logbooks.com.au  and check out the range. A lot better than daily sheets to distribute and collect.

-------------------------
every time you use it it's one less time that it can be used

Posted 12 Apr 2012 02:39 PM Reply  Report this message
gerry_e
norfolk, United Kingdom
just a quick point about keeping shift check sheets, we had a chap who had left the business and was experiencing back problems and wanted to claim that the condition of the seat on the truck was a contributing factor to his injury. We keep the check sheets for the life of the truck (5 years) and could show that he had never once reported that the seat was damaged. i try to get the guys to realise how important it is that the daily check sheet is actually completed and that the checks are done. Its in every bodies interest to really do them.

Posted 10 May 2012 07:24 PM Reply  Report this message
LiftTraining
New Brunswick, Canada
OSHA's requirements for daily inspection of forklifts are in 1910.178(q)(7). But, OSHA does not require that the daily forklift inspections be documented. So it is up to the employer's discretion to determine the duration of powered industrial truck examination record retention. (Reference: 2/7/2000 OSHA Letter of Interpretation)

Posted 11 May 2012 07:55 PM Reply  Report this message
KeyTroller
fl, United Kingdom
Keytroller specializes in devices that force the operator to complete the checklist electronically. The device will record each checklist entry for each operator/vehicle, time-stamp it, and wireless transmit this information for it to be recorded in a computer database. Failed checklist items will automatically send reports to safety and maintenance personnel.

No more worries about legibility, lost paperwork, or negligence.


-------------------------
www.keytroller.com

Posted 29 Jun 2012 05:54 AM Reply  Report this message
calvin_w
Victoria, Australia
If you want a good simple logbook for pre start safety checks I suggest you goto logbooks.com.au where they have books for 1 shift per day x 12 months and 3 shifts perday x 12 months, + lock out tags n ties and pen Great value.

-------------------------
every time you use it it's one less time that it can be used

Posted 5 Jul 2012 04:02 PM Reply  Report this message
tjoldman
Ohio, United States

Here in the states, I have heard 2 months for record retention for paper pre-shifts and I was told once 4 years! I found out later the 4 years was based on a miss-applied ANSI standard written for aerial lift equipment record retention. All the time frames I've heard over the years given by an OSHA office is not based on any applicable law or standard, just a local recommendation. Listening to your local OSHA office recommendation makes a lot of sense. Those are the individuals you will hope to satify in an accident investigation if something happens. I agree with the previous posts saying written or documented pre-shift inspections are not required by the CFR 1910.178. But, OSHA in accident investigations have asked operators if they do pre-shift inspections and what items they inspect. OSHA officers have asked for training information used for training operators and then look for pre-shift inspections to be covered in training. I have heard and read about OSHA officers being satisfied by electronic pre-shift inspections like we see offered by Shockwatch or pre-shift inspection points lists posted on the machine (not dated, just a decal) or maybe a pre-shift list posted on a wall in a battery charging station to help an operator to not forget an item. An employer must have something to point to that supports pre-shift inspections are important, part of their culture, and are being done when OSHA gets involved. A dated, daily, or every shift piece of paper is not required by law. As pointed out in previous posts, dated documentation can have tremendous value in civil cases. Unfortunately in the states, we do not benefit from "loser pays" and every election tort reform never seems to be a real campaign issue. So, just about anything can happen in a civil case. The more documentation you have the better. But, when you do dated daily documentation you have to be perfect. You can't have missed days or missed shifts if the machine was in use. If you have missing records you might have been better off to have no dated records at all! Missing dates or shifts is now documentation that you are not doing pre-shift inspections. The most important thing is that pre-shifts are done. It is foolish to get on a 9000lbs machine, start the engine, release the park brake, throw it in gear, and stomp the accelerator getting the machine up to top speed. That is absolutely a foolish thing to do! Why? Did I say the operator made sure the brake pedal didn't go to floor before putting it in gear? Everybody wins when good pre-shift inspections are completed. Pre-shift inspections should be about common sense first and the question of documentation or not... last. If the employer decides to document, check with your local OSHA office and get their recommendation for suggested record retention.

Posted 9 Aug 2012 11:31 PM Reply  Report this message
Jplayer
North Carolina, United States

here!here!
safety first!
be smart, be safe, live long and prosper
;o)


-------------------------
John Player Jr
_________________
LiftOne, LLC
Charlotte, NC
Email: jplayer@liftone.net


Posted 10 Aug 2012 07:18 AM Reply  Report this message
AceT
Hampshire, United Kingdom

There is no " Set Rule" to follow.

I would recommend that this takes as long as YOU consider given enough time for you to know your working safe.

Its all about your safery...

-------------------------
www.acetrainers.co.uk


Forklift & Driver CPC Training Service's

Transport Consulant Service's


Posted 12 Aug 2012 02:15 AM Reply  Report this message
calvin_w
Victoria, Australia
I agree   that prevention is better than cure.  So have a look at our Forklift /truck safety check and maintenance logbook they are good. Google  logbooks.com.au

-------------------------
every time you use it it's one less time that it can be used

Posted 12 Aug 2012 09:04 AM Reply  Report this message
Jplayer
North Carolina, United States

did some research and found this documentation on OSHA's website at this url
w ww.osha.gov/SLTC/poweredindustrialtrucks/index.html
part way down the page at this url
w ww.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9828#1910.178(l)

in subsection 1910.178(l)(3)
the first question asked and the response from OSHA

Question 1: Is it a requirement that we checkout each forklift with a checklist at the beginning of the workday or is it a requirement for every driver throughout the day to check out the lift each time he gets one?

Reply: 29 CFR 1910.178(q)(7) has a requirement that all powered industrial trucks (PITs) be examined before being placed in service. This examination is required daily or after each shift if the trucks are used on a round-the-clock basis. Although there is no specific OSHA requirement that a checklist be used, an employer does have the responsibility to determine that PITs are properly inspected.


i read through the hole thing and hunted around for any other information and even though they do require the inspection to be done there is no mention that any records be kept or if they are how long they should be retained.

hope this confirms your question and negates any assumptions previously made ;o)


-------------------------
John Player Jr
_________________
LiftOne, LLC
Charlotte, NC
Email: jplayer@liftone.net


Modified 13 Aug 2012 02:12 AM
by poster.
Reply  Report this message
johnr_j
Georgia, United States
Jplayer,
You made an earlier comment while OSHA does not clearly state how long Daily Inspection reports are to be retained, it is advisable to keep records in case a legal situation arises from an incident.  At this time, I would think the best person to determine how long they should be retained would be the company's legal council.  Most OEM's do provide a daily inspection report form for new equipment in some form as CYA practice.   Kinda' like all trucks should have an operator's manual when delivered to an end user, new or used equipment.  While having the manual on the truck may not help one in a legal battle, not having one on the unit can hurt you - this is one reason many manufacturers have the operators manual wired to the truck, typically in the seat back pouch.  While most new trucks will have the manual - not so many used units do.

Modified 13 Aug 2012 11:56 AM
by poster.
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