rick c:

For an official interpretation you would have to contact federal OSHA @ 1-800-321-OSHA (6742) Toll Free U.S.; or go to osha.gov on the internet and click on contact us. Go to "Do You Have Workplace Safety & Health Related Questions?:" and click on the e-mail or electronic mail form to submit your question.

My interpretation is as follows:

The U.S. OSHA regulations do not differentiate between a fixed or removable load backrest extension:

OSHA 1910.178(m)(10): "A load backrest extension shall be used whenever necessary to minimize the possibility of the load or part of it from falling rearward."

There should not be any problem if the load backrest extension comes fixed by the manufacturer. If the employer has the removable load backrest extension welded, the employer could be in violation unless the employer has the manufacturer's prior written approval.

OSHA 1910.178(a)(4): "Modifications and additions which affect capacity and safe operation shall not be performed by the customer or user without manufacturers prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly."

If the load backrest extension is not properly welded, the welds could break causing the load backrest extension and or load to fall on the operator which would affect safe operation. It should be noted that a falling object protection structure (FOPS) on a forklift does not provide full impact protection to the operator.

OSHA 1910.178(m)(9): "An overhead guard shall be used as protection against falling objects. It should be noted that an overhead guard is intended to offer protection from the impact of small packages, boxes, bagged material, etc., representative of the job application, but not to withstand the impact of a falling capacity load."