Regional Emphasis Program (REP) for Powered Industrial Trucks

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U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration
DIRECTIVE NUMBER: BMH-CPL-04-00-002
SUBJECT: Regional Emphasis Program (REP) for Powered Industrial Trucks
REGION: Birmingham Region
SIGNATURE DATE: July 30, 2026 EFFECTIVE DATE: October 1, 2026
ABSTRACT
Purpose: The purpose of this instruction is to renew a Regional Emphasis Program
(R EP) to reduce injuries and fatalities related to powered industrial trucks
in General Industry, Maritime and Construction.
Sc
ope: This instruction applies to all Birmingham Region Federal Area Offices.
References: See Section III.
C
ancellations:
This instruction supersedes OSHA Regional Instruction BHM-CPL-04-00-
002, Regional Emphasis Program (REP) for Powered Industrial Trucks,
April 17, 2025.
State Impact: No Impact
Action Offices: This instruction applies to Baton Rouge, Birmingham, Jackson, Little Rock,
Mobile, and Nashville Federal Area Offices.
Originating Office: Birmingham Regional Office
Contact: Assistant Regional Administrator for Enforcement Programs
By and Under the Authority of
DORINDA HUGHES
Regional Administrator

Executive Summary

Many hazards are associated with the operation of powered industrial trucks, which could lead
to serious injury and death to employees. The intent of this Regional Emphasis Program is to
encourage employers to take steps to correct these hazards thereby reducing potential injuries
and death. We intend to accomplish this through outreach and enforcement activities. Outreach
activities will include letters to employers, training sessions, and possible partnerships or
alliances with stakeholders. Enforcement activities include reviewing powered industrial truck
operations on all inspections where applicable and conducting inspections for complaints that
allege powered industrial truck hazards.

Significant Changes

• Added Baton Rouge, Little Rock Area Offices.
• Updated the OSHA Information System statistical data.
• Updated Bureau of Labor Statistics charts and information.

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Table of Contents

I. Purpose. ............................................................................................................................................... 4
II. Scope. ................................................................................................................................................... 4
III. References. .......................................................................................................................................... 4
IV. Cancellations. .................................................................................................................................. 4
V. Expiration. ............................................................................................................................................ 4
VI. Action Offices. ................................................................................................................................. 4
VII. Federal Program Change. ................................................................................................................ 5
VIII. Significant Changes. ........................................................................................................................ 5
IX. Background. ......................................................................................................................................... 5
X. Procedures. .......................................................................................................................................... 6
XI. Recording in OIS. ................................................................................................................................. 6
XII. Outreach. ......................................................................................................................................... 7
XIII. Evaluation. ....................................................................................................................................... 7
APPENDIX A ................................................................................................................................................... 8
APPENDIX B ................................................................................................................................................... 9

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I. Purpose.
The purpose of this instruction is to reissue a Regional Emphasis Program (REP) to reduce
injuries and fatalities related to powered industrial trucks in General Industry, Maritime
and Construction as part of the OSHA region realignment. This REP will provide the legal
authority to evaluate the employer’s forklift program on all unprogrammed inspections
or other limited scope inspections to assure that employees are being properly protected.
Powered industrial truck (PIT) operations will be inspected on all programmed and
unprogrammed inspections in General Industry, Maritime, and Construction. Area offices
will normally conduct inspections for all complaints, formal or non-formal, which contain
allegations of powered industrial truck hazards, unless there are significant resource
implications. In addition, all unprogrammed inspections may be expanded to include
powered industrial truck operations if applicable.
II. Scope.
This instruction applies to all Birmingham Region Federal Area Offices.
III. References.
A. Title 29 Code of Federal Regulations, Part 1910.
B. OSHA Instruction CPL 04-00-002, Procedures for the Approval of Local Emphasis
Programs (LEPs), November 13, 2018
C. OSHA Instruction CPL 02-00-164, Field Operations Manual (FOM), February 9,
2026, or current update
D. OSHA Instruction CPL 02-00-051, Enforcement Exemptions and Limitations under
the Appropriations Act, July 18, 2024
E. Powered Industrial Truck Operator Training; Final Rule. Federal Register
Tuesday, December 1, 1998; 63(230):66238-66274.
F. ASME (American Society of Mechanical Engineers) B56.1- 2020, Safety Standard
for Low Lift and High Lift Trucks. (www.itsdf.org)

IV. Cancellations.
This instruction supersedes OSHA Regional Instruction BHM-CPL-04-00-002, Regional
Emphasis Program (REP) for Powered Industrial Trucks, April 17, 2025.

V. Expiration.
This instruction expires within five years of the effective date, unless extended.
VI. Action Offices.
A. Responsible Office.
Birmingham Regional Office – Enforcement Programs.
B. Action Office.
Baton Rouge, Birmingham, Jackson, Little Rock, Mobile, and Nashville Federal Area
Offices.

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VII. Federal Program Change.
None.
VIII. Significant Changes.
A. Added Baton Rouge, Little Rock Federal Area offices.
B. Update OSHA Information System statistical data.
C. Update Bureau of Labor Statistics charts and information.
IX. Background.
OSHA estimates there are approximately 1.5 million workers in the United States who
operate powered industrial trucks. Powered industrial trucks are a significant source of
serious and fatal injuries to workers.
A. Statistics.
According to the U.S. Department of Labor/Bureau of Labor Statistics (BLS), TABLE
A-5 of Fatal occupational injuries by occupation and event or exposure, all United
States, for 2024, the number of fatal injuries among industrial truck and tractor
operators was 30. During FY25, Federal OSHA and the State programs investigated
85 fatalities, and 26 other non-fatal incidents related to violations of the powered
industrial trucks standards. During the same period, the Birmingham Region
conducted 65 inspections where powered industrial trucks were used and issued
90 citations related to powered industrial truck hazards.

B. Definition.
Powered industrial trucks are used in almost all industries. They are used to move,
raise, lower, or remove large objects or several smaller objects on pallets or in
boxes, crates, or other containers. OSHA Standard 1910.178 for powered
industrial trucks contains requirements related to fire protection, design,
maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand
trucks, and other specialized industrial trucks. ASME B56.1-1969, Safety Standard
for Low Lift and High Lift Trucks, which is incorporated by reference in 1910.178,
defines powered industrial trucks as “mobile, power propelled trucks used to carry
push, pull, lift, stack, or tier material.”

C. Hazards.
Each of the different types of powered industrial trucks has its own unique
characteristics and inherent hazards. Characteristics of powered industrial trucks
that affect safe truck operation are the truck's tendency to become unstable; its
ability to carry loads high off the ground; and its characteristic mode of steering,
i.e., with the rear wheels while being powered by the front wheels. Moving loads
upward, downward, forward, and backward causes a shift of the center of gravity
and can adversely affect the vehicle's stability. When a load is raised or moved
away from the vehicle, the vehicle's longitudinal stability is decreased.
Workplaces, where powered industrial trucks are used, present a variety of

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different hazards such as, but not limited to, rough, uneven, or sloped surfaces;
unusual loads; hazardous areas; narrow aisles; blind spots; and pedestrian traffic
or employees working close to the path of travel. Some hazardous work practices
relate to all trucks, including driving at excessive speed, poor loading, and carrying
unauthorized passengers. Poor truck maintenance can also contribute to
accidents. Improper truck maintenance has caused death from over exposure to
carbon monoxide, loss of brakes, or rupture of hydraulic lines.
Many accidents have occurred because of unsafe truck operation. For example,
employees have fallen from trucks while using them to change light bulbs on
overhead fixtures or riding on the forks to manually retrieve items from high racks.
In addition, accidents have occurred when an operator attempted driving with an
obstructed view in the direction of travel and has run into another employee.
The Birmingham Regional OSHA Office is reissuing this REP to ensure powered
industrial truck operations are evaluated on all inspections to determine employer
compliance with all relevant OSHA requirements and ensure employees are
protected from powered industrial truck related hazards.

X. Procedures.
The conduct of inspections shall adhere to the following:
A. All inspections conducted in general industry, maritime and construction are
covered by this instruction.
B. During all inspections, compliance officers shall determine if powered industrial
trucks are utilized at that worksite. If they are, the compliance officer will either
expand the inspection or make a referral to cover those operations unless
powered industrial trucks operations have been inspected at the worksite within
the last three years.
C. In accordance with the FOM, Chapter 9, Complaint and Referral Processing, area
offices will normally conduct an inspection for all complaints, formal or non-
formal, which contain allegations of powered industrial truck hazards unless there
are significant resource implications.
D. If an employer refuses to allow the compliance officer to expand an inspection to
address the powered industrial truck operations covered by this program, a
warrant shall be sought in accordance with procedures in the current FOM,
Chapter 15, Section III, for handling such refusals.
E. Area Directors shall ensure compliance officers are sufficiently qualified/trained
to conduct this type of inspection.

XI. Recording in OIS.
Current instructions for completing the appropriate OSHA forms shall be applied when
recording inspections under this REP.

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A. All inspections expanded or scheduled under this REP shall be coded in OIS as
“FORKLIFT” under local emphasis.
B. Unprogrammed activities such as Fatality, Complaint, Referral, and Employer-
Reported referral shall be coded in OIS as “FORKLIFT” in the appropriate field.

XII. Outreach.
All REPs must contain an outreach component that must be ongoing throughout the
effective period of the program. These outreach efforts should be coordinated with or
include the consultation program for that area. The method of outreach is at the
discretion of the respective Area Directors and can consist of one or more of the following
components.

1. Broadcast mail-outs, emails, or program information
2. Stakeholder meetings
3. Targeted training sessions
4. Presentations to the affected group(s)

Before the Baton Rouge and Little Rock Area Offices may initiate enforcement under
this program, each will implement outreach programs supporting the goals of this
program. The outreach efforts should occur at least three months before the initiation
of inspections and continually after.

XIII. Evaluation.
An evaluation of the program will be conducted midway through and at the completion
of the effective period that addresses whether the program advances OSHA’s goals and
initiatives and will include quantitative and qualitative measures.

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APPENDIX A
Date

Company Name
Address

Dear Stakeholder:

The United States Department of Labor/Occupational Safety and Health Administration (OSHA),
Birmingham Region, has developed a local outreach, education, prevention, and inspection program
regarding employers who may have powered industrial truck operations. We will be conducting
outreach efforts to employers to raise awareness of the hazards related to powered industrial trucks.
We are writing to invite you to participate in our outreach efforts.

The goal of the program is to reduce fatalities and serious injuries related to powered industrial trucks
and to encourage employers to bring their facility into compliance with the applicable OSHA regulation
for Powered Industrial Trucks in General Industry, Maritime and Construction. Hazards associated with
powered industrial trucks include: inadequately trained drivers, improper operation (tip-overs, collisions
with structures and pedestrians), improper storage of materials in areas serviced by powered industrial
trucks, use of powered industrial trucks in a hazardous location, inadequate lockout-tagout procedures
while working on powered industrial trucks, carbon monoxide and propane exposures, falls from
powered industrial trucks while elevated, and improper maintenance procedures.

Small employers may contact the On-site Consultation Program for a free confidential safety and health
consultative visit. The consultation program, funded primarily by federal OSHA, provides safety and
health consultative services to help employers establish and maintain a safe workplace by coming into
compliance with OSHA’s regulations. Although the consultants’ findings are confidential, employers are
required to correct any hazards they observe on their visit. Information related to the On-site
Consultation Program may be found at the OSHA website, www.OSHA.gov.

The mission of OSHA is to ensure that working men and women arrive home safe each night from their
place of employment. Together, we can accomplish this task. OSHA shares each employer’s goal of
reducing occupational injuries and illnesses to the maximum extent practical. Should you wish to
participate with us in our efforts or if you have any questions or comments, please contact me at (xxx)
xxx-xxxx. We look forward to working with you toward this common objective.

Sincerely,

Area Director (xxxx)

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APPENDIX B

Powered Industrial Truck (PIT) Inspection Guidance

This guidance provides recommendations for evaluating PITs. The compliance officers shall
familiarize themselves with OSHA standard, 29 CFR 1910.178. The CSHOs shall conduct a
complete and thorough evaluation and inspection utilizing the steps listed below:

Step 1. Determine the types of PITs at the establishment, such as but not limited to; electric
motor rider trucks, order pickers, sit down forklift trucks, walk behind trucks, etc. Reference
1910.178, ANSI/ASME B.56.1 and https://www.osha.gov/etools/powered-industrial-trucks.

Step 2. Determine which employees have been designated to operate the PITs. Determine
through interviews and an evaluation of the employer’s training program their level of training,
experience, refresher training, and evaluation.

Step 3. Inspect one or more of the different types of PITs used in the establishment. The
truck(s) shall be visually inspected to address hazards outlined in the appropriate OSHA
standard. Have an operator and the member of management responsible for the PITs onsite
demonstrate how they perform inspections of the PITs.

Step 4. Observe the PITs in operation for safe operation and handling.

Step 5. Interview the operators. Discuss training, evaluations, incidents/accidents, handling of
defective trucks, and repairs.

Step 6. Interview the employer/trainer. Discuss policies/procedures, training program,
frequency of training, determination of competency when hiring experienced operators,
evaluation of operators, maintenance/servicing of trucks, knowledge of the owner’s manual,
and removal/return of trucks to service.