Powered Industrial Vehicles Local Emphasis Program LEP

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Powered Industrial VehiclesLocal Emphasis
Program (LEP)
Wisconsin Safety Council 66th Conference
Expo Wisconsin Dells, WI April 30, 2008
Mary Bauer CIH, CSP Compliance Assistance
Specialist Eau Claire, WI 54701 715-832-9019
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What is the LEP and why?

• What is a Local Emphasis Program (LEP)?
• What is a PIV vs. a PIT?
• Why focus on PIVs?
• What activities are covered?
• How does the LEP affect my company?
• How is the LEP applied during inspections?
• What is OSHA Doing for Outreach?
• Training Best Practices

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LEP Local Emphasis Program

• CPL 04-00 (LEP 002) PIV
• EFFECTIVE DATE October 1, 2006
• Renewed November 1, 2007
• Expires September 30, 2008
• Scope of Vehicles
• Forklifts
• Earth Moving Equipment
• Over-the-Road Hauling
• Similar Equipment in Operations w/in OSHAs
  Jurisdiction

.
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What is a PIV You Ask?

• PIT Powered Industrial Truck
• Primarily General Industry
• Primarily a Forklift, Pallet Jack
• PIV Powered Industrial Vehicle
• Construction
• General Industry
• Any Industrial Vehicle!

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This LEP is in Effect Now
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Why Do We Need the PIV LEP?

• FY 2005 and 2006
• 54 Fatalities in Region V Related to PIV
• 28 Fatalities in Region V Related to PIT
• OSHA FY 07 Strategic Management Plan
• Nationwide Target to Reduction PIV Fatalities
• Region Vs PIT Program Expanded
• Additional Vehicles and
• States Illinois, Ohio and Wisconsin

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What is expanded with the name change (
PIV vs. PIT )?

• Gen Industry Purposes
• Yard/Dock Vehicles
• Semi Tractors and Trailers
• Log Trucks
• Delivery Vehicles
• Spotting Tractors
• Rough Terrain Lifts
• Skid Steers / Bobcat
• Front End Loaders

• Construction
• Earthmoving Vehicles
• Dump trucks
• Scrapers
• Graders
• Bull Dozers
• Rough Terrain Lifts
• Skid Steers / Bobcat
• Front End Loaders
• Excavators

Is your Chevy S-10 Pickup a PIV?
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What are the Top Causes of Workplace
Fatalities?
Transportation 43 Highway 24
Non-Highway 19
Highway Typically DOT Jurisdiction
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Standards

• OSHA Standards
• 1910.178 Powered Industrial Trucks
• 1926.21 Training
• 1926.600 Subpart O Motor Vehicles/Equipment
• Industry Standards
• ANSI B56.1 Low and High Lift Trucks
• ANSI B56.6 Rough Terrain Forklifts
• AEM Association of Equipment Manufacturers

Appendix A, PIV Information Package, and Appendix
B, Dock Safety Programs
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Hazards Causing Fatalities
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How does the LEP affect my company?

• LEP Does NOT target inspections
• IF on-site for inspection, will review PIV
  program.
• Review consists of
• Training Program
• Observation of Worksite and Operations
• Employee Interviews
• Accident/Near Miss Records

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When Will OSHA Follow This LEP?
(Scheduling)

• Serious Complaint or Referral
• Alleges a Hazard Condition that may be a
  Violation of the PIT or PIV Standard.
• Will up grade a non-serious complaint or referral
• Programmed Inspections Utilizing PIVs
• General Industry
• Construction Worksites

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How is the LEP applied during
Inspections?

• All Aspects Related Standard
• Powered Industrial Trucks (1910.178)
• Powered Industrial Vehicles (1926.60X)
• Associated Standards
• Injury/Illness Info from OSHA-300
• SH Program Evaluation
• LOTO Program Evaluation

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What is Training?

• Training refers to the acquisition of knowledge,
  skills, and competencies as a result of the
  teaching of vocational or practical skills and
  knowledge that relates to specific useful skills.
  
• So.When is training
• ADEQUATE or SUFFICIENT?
• EFFECTIVE or VALUABLE?

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Focused Individuals

• Equipment Operator
• Workers on the Ground
• Directly working with Equipment
• Passer-By / Foot Traffic
• Yard Workers Inventory, QA, etc.
• Subcontractor Employees
• Maintenance /or Troubleshooting
• Transporting Equipment from Job-to-Job

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What Activities or Tasks are Covered?

• Operations
• Training of Operator
• Use, Application, Parking, Storing, etc.
• MISUSE!
• Fueling
• Battery or Propane
• Maintenance
• Inspection Program Daily and Preventative
• De-energization of Vehicle
• Worksite Design
• Struck-By and Caught In Between
• Foot Traffic

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Tasks Be Specific!

• Loading / Unloading Trailers
• Flat beds
• Curtain sides
• Closed van
• Straight truck
• Open top
• Rail cars

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Tasks Be Specific!

• Types of Materials Handled
• Different widths / lengths of Material(s)
• (8, 12, 16, etc.)
• Metal
• Wood
• Vinyl
• Glass
• Dumpsters

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Tasks Be Specific!

• Specific tasks
• Stacking on racking
• Handling bundles, pallets, etc
• Loading / taking away from chains / conveyors
• Dumping dumpsters
• Stacking on spacers outside
• Carrying / moving loads

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Inspection Guidelines perTraining Directive
1910.178(l)

• Training Programs Method Implementation
• Formal Instruction ( Classroom Written Test )
• Practical Training ( Hands On Evaluation/Test
  ) Training
• CPL 2-1.28A Compliance Assistance PIT
• http//www.osha.gov/pls/oshaweb/owadisp.show_docum
  ent?p_tableDIRECTIVESp_id2277
• Knowledgeable Person Conducted Training
• All Topic in 1910.178(l)(3) Covered
• Truck Related Topics
• Workplace Related Topics
• Operators Manual ( Must have one! )
• Operating Instructions
• Warnings Precautions
• SEAT BELT USE

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Restraints or Seat Belts
Enforcement of the Use of Seat Belts on Powered
Industrial Trucks in General Industry October 9,
1996

• OSHA's enforcement policy on the use of seat
  belts on powered industrial trucks is that
  employers are obligated to require operators of
  powered industrial trucks that are equipped with
  operator restraint devices, including seat belts,
  to use the devices.

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Maintenance ALSO Covered! SHIB Safety and
Health Bulletins

• Hazards of Unintended Movement of Dump Truck Body
  Beds SHIB 09-18-2006

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Training/Interview Questions

• Classroom and Practical
• Verification of Learning i.e. Written Test
• Qualified Trainer
• Preamble encourages in-house trainers-More
  Familiar
• Evaluation
• Certification
• Truck Specific
• Work Place Specific
• Evaluations
• Supervision Disciplinary/Near Misses

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Training Program

• Formal Instruction (test included)
• Lecture
• Video
• Written Material
• Interactive Computer Learning
• Practical Training Exercises
• Evaluation of Performance in Workplace

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Program Content

• Truck-Related Topics
• Site-Specific Topics
• New Hire Training
• Refresher Training
• Operator Certification

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Trainers Qualifications

• To train operators evaluate competence,
  trainers must have
• The knowledge
• The training
• The experience
• Evaluators Demeanor
• Calm
• Over Protective

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Initial TrainingTraining Implementation (l)(2)

• OSHA Standard May Operate a Lift when
• Under Direct Supervision
• Where not danger to trainee or others..
• Best Practice
• Orange Vest Period ( Probationary )
• List of Tasks Evaluated
• Assigned Coach or Mentor

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Who Do You Train?

• Full Time Operators
• High Volume Warehouse
• Order Pickers / High Lifters
• Intermittent Users
• Production Line ( Raw Material Finished Goods)
• Periodic Truck Un/Loading
• Sit Downs
• Maintenance Staff
• Special Projects or Tasks (Darwin Awards)
• Pedestrians Foot Traffic Best Practice

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Whos Error?

• PIT Op
• OTR Driver
• Policy
• Supervision
• Training

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Pedestrian Traffic Lift Operator

• Yield right of way to pedestrians.
• When a person or group of people walk across your
  planned route
• Stop traveling
• Lower the load to the floor
• Wait until the pedestrians pass by
• Proceed cautiously through any congested area
• Operate ONLY as fast as conditions safely permit
• Be constantly alert to changing or unusual
  conditions

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Pedestrian Traffic - Pedestrian

• Establish Eye Contact with Operator
• Driver's visibility may be limited and may not
  see you.
• Be aware that lift trucks can not stop suddenly.
• Never approach a powered industrial truck from
  the rear because the back end can swing around
  suddenly.
• Both look and listen for lift trucks. Be aware
  that you may not always hear them.
• Yield the right-of-way to powered industrial
  trucks.
• Use Designated Walkways, or stay to one side of
  the equipment aisle.
• Never pass under an elevated load.

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Truck Related Topics

• Operating instructions, warnings, and precautions
  for the types of truck the operator will be
  authorized to operate
• Differences between the truck and the automobile
• Truck controls and instrumentation where they
  are located, what they do, and how they work
• Engine or motor operation
• Steering and maneuvering
• Visibility (including restrictions due to
  loading)
• Fork and attachment adaptation, operation, and
  use limitations
• Vehicle capacity
• Vehicle stability
• Any vehicle inspection and maintenance that the
  operator will be required to perform
• Refueling and/or charging and recharging of
  batteries
• Operating limitations
• Any other operating instructions, warnings, or
  precautions listed in the operator's manual for
  the types of vehicle that the employee is being
  trained to operate.

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Truck Specific w/ Attachments
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LP Tank Orientation Pressure Relief Valve at the
1200 Position
If the valve operates, the vapor will come out
and not the liquid
Slot not Place on Locator Pin
Slot Correctly Placed on Locator Pin
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Workplace Related Topics

• Surface conditions where the vehicle will be
  operated
• Composition of loads to be carried and load
  stability
• Load manipulation, stacking, and unstacking
• Pedestrian traffic in areas where the vehicle
  will be operated
• Narrow aisles and other restricted places where
  the vehicle will be operated
• Hazardous (classified) locations where the
  vehicle will be operated
• Ramps and other sloped surfaces that could affect
  the vehicle's stability
• Closed environments and other areas where
  insufficient ventilation or poor vehicle
  maintenance could cause a buildup of carbon
  monoxide or diesel exhaust
• Other unique or potentially hazardous
  environmental conditions in the workplace that
  could affect safe operation.

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Refresher Training

• Evaluated Once Every 3 Years
• Unsafe Operation is Observed
• Accident or Near-Miss Occurs
• Retraining/Coaching vs. Disciplinary Action
• Evaluation Reveals Unsafe Operation
• Assigned to New Type of Truck
• Changes in Workplace Conditions

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Near Miss

• Definition ?
• near miss n. \
• 1. Narrowly avoided collision
• 2. A missile strike that is extremely close to
  but not directly on target.
• 3. Something that fails by a very narrow margin
• Need System to Identify, Recognize, Report and
  Monitor for Near Misses
• BEST PRACTICES
• Dont find Fault
• Drives Items Underground
• Perform Accident Investigation as if an Accident
  Happened
• Use as Process Improvement / Suggestions

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Accident

• Definition ?
• Dollar Value?
• Swap Paint?
• Recordable Injury?
• accident n.
• 1. a. An unexpected and undesirable event,
  especially one resulting in damage or harm car
  accidents on icy roads.
• b. An unforeseen incident
• Accident Investigation Conducted

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Format Adult Learning Theory

• Classroom

• Practical

Combined Format Short Clip then Discussion
Short Attention Spans Follow Along Tests-Answer
as You Go Learn by Doing i.e. Use the actual Lift
to Demonstrate Inspections QA Draw out the
Students Knowledge Skills Testing Forklift Rodeo
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CBT Computer Based Training

• Pros
• Good for Make-Ups
• Good for Track Purposes
• Standardization
• Frees up Personnel for Orientation Topics
• Younger Generation has Used this Method

• Cons
• Need Computers and/or Computer Lab
• Lacks interaction
• Questions dont get asked
• Needs to be away from Workstation-Relief Staff
• Still needs Evaluation

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How to Motive Keep Attention

• Case Studies
• Accidents
• Near Misses
• Fatal Facts
• FACE / NIOSH Reports
• Real Life Situations / Scenarios
• Before / After / Corrective Methods
• Identify w/ Individual

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FATAL FACT Crushing

• While one employee was loading a bobcat onto a
  trailer the victim noticed that the trailer hitch
  safety latch was not in the locked position. In
  an attempt to lock down the trailer hitch the
  victim reached over the trailer snapped the
  trailer tongue upward catching the victim head
  between the trailer tongue the underside of the
  truck bed killing him.

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What can you see happening here? An operator
worker has parked a lift truck at a right angle
to a truck on a road having inclination of 6
degrees. He helps unfasten the ropes affixed to
the cargo on the truck. Now what can you see
happening from this picture?
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The lift truck started to slowly move forward, as
it was parked facing downward on the slope. One
of the fork tines thrust the operator against the
truck body and injured him.
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Corrective Actions

• Tips for eliminating similar accidents
• 1. Lower the fork to the ground, apply the
  parking brake tightly, stop the engine and pull
  out the engine starting switch key, whenever
  leaving the operator's seat.
• 2. If it becomes necessary to park a lift truck
  on a slope, place chocks before or behind the
  wheels, as the case may be.

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How to Motive Keep Attention

• Testimonials
• Co-Workers/Peers Explaining Bad Situations
• Eddie Adams Fatality for Arc Flash
• Widows/Widowers/Children
• Keep it Personal
• Use familiar faces, names, videos, photos

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Video Clips

• Actual Events
• Security Cameras by Docks and Yards
• Y-Tube
• Desired Behaviors of Company Employees
• Immediate Connection to Co-Workers and Worksite
• Role Model

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Motivation Interest Warped Humor - Contrast
Everyone has the responsibility to make sure the
switch in the head is in the on position before
we proceed!
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Far Fetched
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Slogan Situational Awareness
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Beyond Stupid Darwin Awards
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Kaizen Event

• The company had incorporated the Japanese concept
  of Kaizen (meaning "gradual, orderly and
  continuous improvement") into the workplace in
  the 1970's. The Kaizen concept focused on
  continuous improvement of the workplace by
  eliminating waste in all systems and processes.
  The ergonomics training was viewed as an effort
  to reduce "wasteful motion in work activities."
• Focused Task Force of All Affected Parties
• Work Smarter Not Harder

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Kaizen Event Roll Damage Costing Money

• Identified Related Issues Resolutions
• Side Loader Sit Downs
• Visibility Camera
• Attachments
• Clamps, Tines, Antlers
• Related Damage-Racks, Equip, Backrest
• Unsecured Rolls on Tines
• Stacking/Storing

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Tips for Program Evaluation

• Training
• Condition of Pallet Racking, Columns, Walls
• Warehouse/Yard Stacking-Storage
• Inspection
• Items and Frequency Noted
• Maintenance
• Oil on Floor
• Notes on Inspection Forms
• Additional Lifts Available if One is Taken Out
  of Service

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Operator Certification

• Employer certifies that each operator has been
  trained and evaluated as required
• Certification Includes Minimum Requirements
• Operator Name
• Training Date
• Evaluation Date
• Trainer/Evaluator Name(s)
• Trainers Qualifications
• Truck Type Certified to Operate

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Evaluation

• BEST PRACTICE
• List of what Topics were Evaluated
• Concentrate on the Operator and surroundings and
  then refer to the check list.

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Evaluation Elements

• Pre-shift Inspection Procedures
• Attitude
• Confidence
• Entry/Exit ( Mounting/Dismounting )
• Starting/Stopping
• Controls
• Turning
• Pedestrian Awareness
• Body Position for Type of Equipment
• Understands Hazards
• Instrumentation

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Evaluation Elements

• Speed
• Hands/Feet with in the Overhead Guard
• Load Handling
• Fork Position
• Load Positioning
• Blind Intersection Procedures
• Traveling Procedures
• Observing Direction of Travel
• Within Capacity Limitations
• Seatbelt Usage when Appropriate
• Parking Procedures

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Inspections Is a written record required?
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Inspection Records

• BEST PRACTICES
• Written Use Owners Manual for items to check
• Proves it was Done
• OSHA
• Shows Some Level of Supervision
• Tracks Defects
• Money Time Spent
• Reoccurrences Preventive/Predictive Maintenance
• Report Back to the Identifying Person

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Summary

• All Operators Must Be Trained
• OSHA Standards are Minimum Training
• Best Practices Include
• Written Test, Inspection Records, Evaluations
• Train Affected Individuals
• Frequent Observations
• Focus on Highest Risk Areas Kaizen Events
• Human Performance Factors

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Directives References

• CPL 04-00 (LEP 002) Region V LEP-PIV
• CPL 2-1.28A
• Compliance Assistance for PIT Driver Training
  Standard
• STD 01-08-002 First Aid and Medical Service
• Battery Handling
• STD 2-1.30 Chocking of Trailers
• STD 01-11-007 Mechanical Means to Secure
• STD 01-05-016 Venting LP to the Atmosphere

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Safety Health Topics -PIT
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QUESTIONS
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Disclaimer

• This information has been developed by an OSHA
  Compliance Assistance Specialist and is intended
  to assist employers, workers, and others as they
  strive to improve workplace health and safety.
  While we attempt to thoroughly address specific
  topics or hazards, it is not possible to include
  discussion of everything necessary to ensure a
  healthy and safe working environment in a
  presentation of this nature. Thus, this
  information must be understood as a tool for
  addressing workplace hazards, rather than an
  exhaustive statement of an employers legal
  obligations, which are defined by statute,
  regulations, and standards. Likewise, to the
  extent that this information references practices
  or procedures that may enhance health or safety,
  but which are not required by a statute,
  regulation, or standard, it cannot, and does not,
  create additional legal obligations. Finally,
  over time, OSHA may modify rules and
  interpretations in light of new technology,
  information, or circumstances to keep apprised
  of such developments, or to review information on
  a wide range of occupational safety and health
  topics, you can visit OSHAs website at
  www.osha.gov.

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