Does 1910.178 apply to personnel and other equipment moving equipment?

OSHA answers the following questions as they relate to 1910.178 Powered Industrial Trucks

Does OSHA standard 29 CFR 1910.178 apply to the following equipment:

A vehicle designed to convey both personnel and equipment, such as welding equipment (Pack Mule Industrial Electric Vehicle: Models covered: SC-775, SCT-7750);
Motorized shopping cart trolley/collector (Dane Technologies, QuicKART: Models covered: M3, M3 E, and M3 HD); and
Motorized cart used to move racks and cages (Master Mover, Stainless Steel Smart Mover: Models covered: Z60-00100,Z60-00101, Z60-00102).

Scenario: In an OSHA interpretation letter dated June 27, 2011, OSHA noted that “ANSI / National Golf Car Manufacturers Association (NGCMA) Z130.1-2004 defines a golf car as, “a vehicle used to convey a person or persons and equipment to play the game of golf in an area designated as a golf course.” Golf cars are considered by design to be recreational vehicles and are exempt from 29 CFR 1910.178. Again, it is the design of the vehicle that is the determining factor of whether or not it is considered a powered industrial truck, rather than the manner in which it is utilized.

OSHA’s short answer is YES; 29 CFR 1910.178 applies to the equipment listed above. Here is their reasoning.

NOTE: some emphasis is by me and some links have been added for ease of access to referenced documents/sources

Question: Does OSHA standard 29 CFR 1910.178 apply to the following equipment:

A vehicle designed to convey both personnel and equipment such as welding equipment (Pack Mule Industrial Electric Vehicle: Models covered: SC-775, SCT-7750);
Motorized shopping cart trolley/collector (Dane Technologies, QuicKART: Models covered: M3, M3 E, and M3 HD); and
Motorized cart used to move racks and cages (Master Mover, Stainless Steel Smart Mover: Models covered: Z60-00100,Z60-00101, Z60-00102).

Response: YES

29 CFR 1910.178 applies to the equipment listed above.

29 CFR 1910.178(a)(1) states,

“(t)his section contains safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines.”

Furthermore, ANSI B56.1-1969 (incorporated by reference into 29 CFR 1910.178) defines a “powered industrial truck” as a “mobile, power-driven vehicle used to carry, push, pull, lift, stack, or tier material.”

The equipment referenced above is powered by electric motors and designed to carry, push, or pull material and is thus subject to the requirements of 29 CFR 1910.178.

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