JH,

Thanks much for a very through and thoughtful response to the question. I appreciate the references. There's certainly enough responsibility to go around, but we still seem to hear of CO poisoning incidents far too often.

The audience may be interested to know that there are relatively inexpensive (<$300) aftermarket upfits for older lifts that add an O2 sensor in the exhaust and effectively make the pre-2002 engines 'closed loop'. This will keep them closer to stoichiometric air/fuel mixtures and in tune longer.

Thanks again.

WHM

afvman:

Since the label would probably carry a WARNING rather than a DANGER or a CAUTION, I do not perceive the need for such a label. (See OSHA 1910. 145 - Specifications for Accident Prevention Signs and Tags.)

If the product of combustion engine hazard is properly covered in the engine/forklift manuals, the product literature, the fuel material safety data sheet, and in the operator training program; this should be sufficient to address the potential problem.

afvman:

All parties involved in the manufacturing, distribution, and servicing of the forklift have some responsibility to warn of the products of combustion hazard. I can't currently put my fingers on specific laws and regulations. I am sure that in this litigious society, however, there are many lawyers ready and waiting with case law and legal precedent to establish the following responsibilities in civil cases:

The forklift engine manufacturer has a responsibility to inform the forklift manufacturer and end user of the product of combustion hazard. This information should be in the engine maintenance and repair manual. I would recommend it also be included in the product literature.

The forklift manufacturer has a responsibility to inform its forklift distributors/dealers and forklift end users of the product of combustion hazard. This information should be in its forklift operating, safety, and repair manuals. I would recommend it also be included in the product literature.

The forklift distributor/dealer and its sales personnel have a responsibility to inform the buyer or prospective buyer of the product of combustion hazard. I recommend such information be part of the sales contract.

Service technicians have a responsibility to inform management if they observe forklifts being operated in a manner that could result in a product of combustion incident. I recommend any such action be documented.

Company trainers (and independent trainers) have a responsibility to adequately instruct the forklift operators in the product of combustion hazard. I recommend that this topic, and all other training topics covered, be thoroughly documented.

afvman:

OSHA 1910.1200, Hazard Communication, also establishes responsibilities for chemical manufacturers and importers of chemicals and chemical mixtures. These chemicals include fuels for internal combustion engines. The chemical manufacturers or chemical importers must evaluate the chemical hazards and provide hazard information in the form of a material safety data sheet (msds) to their downstream users.

OSHA 1910.1200, Hazard Communication, also requires chemical distributors of such products to provide the MSDS hazard information. 1910.1200(g)(7)(i) "Distributors shall ensure that material safety data sheets, and updated information, are provided to other distributors and employers with their initial shipment and with the first shipment after a material safety data sheet is updated."

Some Material Safety Data Sheets do an excellent job in providing the products of combustion hazard. "WARNING: the burning of any hydrocarbon as a fuel in an area without adequate ventilation may result in hazardous levels of combustion products, including carbon monoxide, and inadequate oxygen levels, which may cause unconsciousness, suffocation, and death." (Amerada Hess Corporation, Material Safety Data Sheet, Low Sulfur Diesel Fuel, MSDS No. 9904).

Some material safety data sheets provide basic warning. "Carbon monoxide and unidentified organic products may be formed during combustion." (Ferrellgas Material Safety Data Sheet - Propane.)

Too many Material Safety Data Sheets fail to convey adequate engine combustion hazard information.

afvman:

The primary responsibility for employee health and safety, including safeguards for the hazards of products of combustion, rests with the employer using the forklift.

Under the U.S. OSH Act "General Duty Clause", SEC. 5. Duties (a). "Each employer - (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act."

The scientific community has long recognized the hazards of internal combustion engine exhaust emissions. Exposure limits have been established by OSHA for many of these exposures, including carbon monoxide, and can be found in OSHA 1910.1000 - Air Contaminants.

OSHA 1910.1200 - Hazard Communication is another standard that requires employers to train employees on the hazards and safeguards of the chemicals and mixtures to which they are or may be exposed.

1910.1200(b) "Scope and application." 1910.1200(b)(1)."This section requires...all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, material safety data sheets, and information and training."

Such hazardous chemicals would include internal combustion engine fuels such as bio-diesel, compressed natural gas, diesel fuel, ethanol, gasoline, liquefied natural gas, liquefied propane gas, and methanol.

OSHA Part 1910.178 requires that forklift operators be trained. 1910.178(l)(3). Training program content. "Powered industrial truck operators shall receive initial training in the following topics, except in topics which the employer can demonstrate are not applicable to safe operation of the truck in the employer's workplace. 1910.178(l)(3)(ii)(H) Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust;"

The ANSI/ITSDF publication B56.1-2005, Safety Standard for Low Lift and High Lift Trucks, also establishes employer responsibility for training in this area: ITSDF B56.1-2005, 4.19. Operator Training 4.19.4." The training program shall emphasize safe and proper operation to avoid injury to the operator and others and prevent property damage, and shall cover the following areas: (13) hazards due to production of carbon monoxide by internal combustion engines and common initial symptoms of exposure."

ITSDF B56.1-2005 5, OPERATING SAFETY RULES AND PRACTICES 5.2.25. "The exhaust from all internal combustion engines contain carbon monoxide, a colorless, odorless, tasteless, poisonous gas. Exposure to carbon monoxide can cause serious injury or health problems, including death. (a) Carbon monoxide can become concentrated in areas such as trailers, containers, coolers, freezers, and poorly ventilated rooms or buildings. Therefore, limit internal combustion engine usage in those areas. (b) Common symptoms of carbon monoxide exposure may include headache, dizziness, and nausea. The smell of internal combustion engine exhaust means carbon monoxide could be present. (c) If an operator experiences these symptoms, move him into fresh air, seek medical attention as required, and contact your employer so he can monitor "threshold limit values." (Consideration should be given to shutting off the operator's internal combustion engine.)"