Joseph,

I noticed last night that there is a viewing option for the guidelines, and that is great, but having the hard copy works better for me.

No sense stating our differences. I still follow the -04 guidelines, and I know of many business who do not follow these guidelines at all.

Since -04 changed the refresher training from 2-3 years, and everybody has jumped on the bandwagon, I guess the -04 rules. Or, maybe everyone just cherrypicks which paragraphs works best for them. lol

As stated, these are just guidelines but the Ontario Ministry of Labour enforces them.

The following site allows free access to any person to view online in full detail the majority of the CSA Safety Standards referenced by Canadian OHS agencies. The standards can be read in detail with no charge. The site blocks printing so the standards cannot be copied using the print command. A person must register (no cost) to use the service. Thereafter, the person must sign in using their e-mail address to access the site.

This is the Canadian Standards Association (CSA) ohsviewaccess.csa.ca/ web page welcome message:

"Welcome to View Access - where you can view CSA standards referenced in federal, provincial and territorial Occupational Health & Safety (OHS) regulations.

* See what applies in your jurisdiction
* Learn about the standards requirements
* Link to other helpful resources

This pilot site was developed by CSA in collaboration with all government departments responsible for OHS. It provides easy access to CSA occupational health and safety standards to:

* ensure that all employers and workers can quickly find regulatory requirements
* foster compliance with these standards"

To view CSA B335-94 Industrial Lift Truck Operator Training or CSA B335-04 Safety Standard for Lift Trucks, Google: VIEW CSA STANDARD REFERENCE IN OHS REGULATIONS - WELCOME or Google: ohsviewaccess.csa.ca/.

This site also allows a person to direct link to the web sites of the various Canadian OHS agencies.

CSA B335-94 is 13 pages. CSA B335-04 is 52 pages. The CSA B335 2004 edition is a major revision of the CSA B335 1994 edition.

For information purposes, the operator shutdown procedures for CSA B335-94 read as follows.

Canadian Standards Association (CSA)
CSA B335-94 Industrial Lift Truck Operator Training

"4.2.3 Shutdown Procedures
The trainee shall be instructed on the correct steps to safely shut down and park the lift truck. The lift truck shall be parked with the parking brake set, transmission/directional control lever in "Neutral", and the fork/mast lowered to the ground and tilted forward. Precautions shall be taken to prevent unauthorized persons from operating the machines. This can be by key removal or other appropriate measures, such as closing the liquid propane gas (lpg) cylinder valve."

I purchased my copy in August of 2004. It was released in May 2004. Late 2004, early 2005 I started to receive many phone calls about some new legislation. I asked how they heard about it and they said that the Ontario Ministry of Labour came around and asked if they were aware of it. Naturally, their answers were 'NO'. They called me up and wondered what changes were made to the CSA B335-04 over the old one, CSA B335-94. I just mentiobed that the refresher dates have changed, and that all the rules that apply to the safe operaion of powered industrial lift trucks haven't changed, except that they are more explicit.

The average Joe cannot access B335-04 on-line. It msut be purchased and recived as a CD, or a download option. Either way, $75.00+tax (7%) buts the guidleines. If a governmental agency has access to this file great, but for the rest of us, we are obliged to pay.

CSA B335-04 replaces CSA B335-94 only by the Canadian Standards Association. If a governmental agency does not adopt by reference the change, the revision would not apply in that jurisdiction.

The Canadian Standards Association (CSA) has a web site allowing any CSA standard referenced by a Canadian governmental OHS program to be reviewed (view-only) online without having to purchase the document. It will also indicate any new edition of a standard if the standard referenced has been revised and not yet referenced by the governmental OSH agency.

It would be highly beneficial if the other standard development agencies throughout the world would follow in the above practice.

Google: (View CSA Standards Referenced in OHS Regulations - Welcome) to review CSA B335-94: Industrial Lift Truck Operator Training or CSA B335-04 Safety Standard for Lift Trucks. Register and search the jurisdiction Ontario.

CSA B335-04 replaces CSA B335-94. the -94 represents 1994, when the document was released, and the -04 represents 2004, when the current document was released. Therefore, the new document overrides the older one, and if I am not mistaken, all of Canada follows the -04 recommendations. At least, here in Ontario, as well.

4.9.11 (e)...AND the key removed 4.9.12.2(c) return the key to the OFF position:AND (d) REMAIN in the immediate vacinity (within 1 truck length) and in ful view of the truck. Very gray and open to discussion in the court of law.

I, as an operator, would be extremely nervous if I left the key in the ignition, and a non-authorized individual jumped on a forklift, and crashed. Whoever was the last to use the forklift, and did not properly secure the forklift in case of 'accidental' movement, would likely be the culprit in participating in this incident.

An incident took place back in June north of Edmonton, Alberta, where 2 yard hands, not certified, jumped on the forklift, and it tipped. They were not authorized to operate the forklift. The truck tipped, and a 16 year old died. Therefore, the company is liable for failing to protect the health and safety of its staff, and probably because there was no in-house policy/procedure guidelines to enforce the staff to remove the key from the forklift when more than 25' away, or the truck is out of view. I would be very concerned if I was the company, and I would also be concerned if I was the last user of this forklift. It is widely known, view any safety video, that the key must be removed from the ignition. This would be considered industry standard practice.

And since these guidelines, as well as the laws are not clearly written in black and white, it leaves the guidelines open to interpretable, and any Philadelphia lawyer will use it to incriminate the faulty parties.

The Canadian Standards Association CSA B335-04 Safety Standard for Lift Trucks does not require a removable key ignition switch.

"4.9.11 Shutdown Procedures, (e) The engine shall be stopped or the controls shall be turned off and the key removed."

The use of the word "or" only requires at a legal minimum that the engine is stopped. Removal of a key is a recommended safe practice where a removable key is involved. It is not legally enforceable if the engine is off.

The CSA Safety Standards are advisory consensus standards developed by the Canadian Standards Association. This is a private, non-governmental association that produces a wide variety of recommended safety practices. These safety standards and any revisions or updates are not automatically enforced by the Canadian federal, provincial or territorial governments. The standards become legally enforceable only if they have been adopted by a governmental body through the legislative process (adopted by reference).

To my knowledge, the Province of Prince Edward Island and the Yukon Territory are the only Canadian governmental bodies that have adopted by reference CSA B335-04, Safety Standard for Lift Trucks. The older CSA B335-94, Industrial Lift Truck Operator Training is the standard that has been adopted by the majority (not all) of the remaining Canadian governmental OHS agencies.

Governmental bodies that have not adopted by reference a CSA Safety Standard often refer to a CSA Safety Standard as a recommended (non enforceable) safe practice. The Ontario Ministry of Labour has issued such a guideline. Google: "Guideline for the Safe Operation and Maintenance of Powered Lift Trucks." In the Part 3, Safety Program, Training portion of this document the Ontario Ministry of Labour makes the following referral: "The Canadian Standards Association also has a training standard (Industrial Lift Truck Operator Training B335-94), which may be useful in designing or evaluating training programs." This document was issued in 1999 and the referral has not been updated to the CSA B335-04 Safety Standard for Lift Trucks.

Removable key ignition switches are not required on lift trucks in Canada or the United States.

ANSI/ITSDF B56.1-2005
Reaffirmation of ASME B56.1-2004

7.19 Travel Controls: Electric Trucks, Sit-Down Rider
7.19.3 A manually operated switch (may be key type) to disconnect all control circuits shall be provided.

7.20 Travel Controls: Electric Trucks, Stand-Up Rider
7.20.3 A manually operated switch (may be key type) to disconnect all control circuits shall be provided.

7.21 Travel Controls: Internal Combustion-Powered Industrial Trucks, Sit-Down Rider
7.21.3 A manually operated engine shut-off device (may be key type) shall be provided.

7.22 Travel Controls: Internal Combustion-Powered Industrial Trucks, Stand-Up Rider
7.22.3 A manually operated engine shutoff device (may be key type) shall be provided.

7.23 Travel Controls: Electric Motorized Hand, Hand/Rider, and Low Lift Order Picker Trucks
7.23.7 Means readily accessible to the operator shall be provided to shut off all power to the truck.

7.24 Controls: High Lift Operator-Up Trucks
7.24.5 A manually operated switch (may be key type) to disconnect all control circuits shall be provided.

Nooooooooooooooo! I'm just kidding! He's closer to us than he is to the rest of the U.S. And his weather is more in line with ours, than say, Texas, Arizona, California and most of the states south of I-80, I-90 corridors. lol

At least in the US fed OSHA regulations and letters of clarifications I have seen, the requirement is to disable the machine when parked unattended, and removing the key if possible is just one more method of insuring "the controls are neutralized" and power is disabled.
In the US [29CFR1910.178(m)(5)(i) ] reg, it states "When a powered industrial truck is left unattended, load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if the truck is parked on an incline."
So,,, removing the key is one more way to insure the "controls are neutralized", but removing the key is NOT specifically spelled out as part of "the law".
One other thing I note and wonder about sometimes...
"Industrial trucks shall not be altered so that the relative positions of the various parts are different from what they were when originally received from the manufacturer, nor shall they be altered either by the addition of extra parts not provided by the manufacturer or by the elimination of any parts, except as provided in paragraph (q)(12) of this section. " SO how many time have you seen a horn button moved to an after-market button on someplace other than the center of the steer column, or the foot button some manufacturers use, and did you deadline that truck?

Further, any OSHA inspector that insisted a truck had to have an amber flashing light and back up motion alarm, most likely is not a real OSHA inspector, but is a "ringer" trying to sell their (or someone they are in cahoots with) services. They (and we) all know 'if it is there, it has to work', but any OFFICIAL OSHA inspector, that has done more than 3 inspections, should know what the regulation really says. just ask them to point out where motion alarm is stated in the regulation.

And Dan-M, are you confusing "New Hampshire" with "New Brunswick"? ;-) ,
-All- them cold "New" places look like Canada to me, says the guy that grew up in the Fla. Keys, about as far from Canada as we can get and still be in the US "lower" 48.

Those so-called options are required only when it will further minimize the chance of incidents in the workplace. If it is deemed necessary for any one particular environment, the feds would 'strongly' suggest it, and we all know what that means.

Isn't New Hampshire closer to Canada than the United States? lol

Danny

Although I believe Canada is a wonderful and beautiful country* New Hampshire is still part of the United States and thereofre not bound by Canadian regulations.
Speaking of regulations; Try asking an OSHA inspector if a strobe light or Back up alarm are required. They all say yes emphatically. Will someone please show me where that is written. If it were the case why are they both "options" in my price books?

*I'm not just saying that-I've travelled from Nova Scotia to Vancouver

It is industry standard that when the truck is unattended, the key must be removed.

Also, each and every safety film says the same as well. And, according to CSA B335-04, 4.9.11, shutdown procedures, the engine shall be stopped or the controls shall be turned off and the KEY removed. 4.9.12.2, when an operator is required to leave the operator's position for such purposes, the operator shall.......(c) return the key to the OFF position, and (d) remain in the immediate vicinity (usually within one truck length) and in full view of the lift truck and its load.

Since the provincial governments follow and enforce the CSA guidelines, then it is mandatory that this practice is in effect.

And some other researchers on this site can probably find the same in the OSHA requirements. I do not believe that the Canadian Government is the first and foremost experts in this area. lol

Therefore duodel, I suggest you give up your day job and start selling those keys. lol lol lol

Danny

Forklift Training Consultant

If they ever enact a regulation that a key must be removed from an unattended forklift truck then that is the day that I'll start a new venture...selling forklift truck keys...cause there will be a HUGE demand.

Thanks. That is probably what they have. They have a bunch of these trucks with many operators. I teach them that when the operator is more than 25' away from the forklift, or the forklift is out of view, it is considered unattended, and the key is to be removed, and presto, they have a type of key that is non-removable.

Kind of contradicting to the laws.

Dan what you have on your lift is a toyota original "keyless switch". You can contact your local Toyota dealer to get a new one your change it for a "standard type". Part number code 5701-15.