The short answer: 29 CFR 1910.178(q)(7) requires that industrial trucks be examined before being placed in service and not placed in service if the examination shows any condition that adversely affects safety, with the examination made at least daily, or after each shift where trucks run around the clock. The check covers the truck cold (visual and fluids) and running (brakes, steering, horn, lights, warning devices, hydraulics), and any defect found triggers 1910.178(p)(1): the truck is taken out of service until it is restored to safe operating condition. Use the grouped checklist below as the body of the examination.
An examination is only as good as the response to what it finds. Work through the groups in order, tag anything that fails, and keep the two governing clauses in view: 1910.178(q)(7) sets the frequency and the "do not place in service" rule, and 1910.178(p)(1) sets the "take out of service" rule for anything found defective during the shift.
What does the pre-shift inspection have to cover?
The examination has two halves: a cold, key-off walkaround and an operational check with the truck running. The items below reflect OSHA's powered industrial truck pre-operation guidance and apply to a typical counterbalance, reach truck, or order picker; add the power-source items that match your fleet.
Key off (visual walkaround):
- Tires and wheels for wear, cuts, or low or flat condition
- Forks for cracks, bends, or excessive wear, and the heel and locking pins
- Mast, chains, and rollers for damage, wear, or a chain that is stretched or out of adjustment
- Load backrest extension and overhead guard present and undamaged
- Hydraulic lines, hoses, and fittings for leaks or damage; the floor under the truck for fresh puddles
- Operator restraint (seatbelt) present, undamaged, and functional
- Data (capacity) plate present and legible, and warning decals in place
Power source (match to the truck):
- Fluid levels: engine oil, coolant, and hydraulic fluid on internal-combustion trucks
- Fuel system: LPG tank secure and its hoses and connections free of leaks; diesel or gas fuel level and no leaks
- Battery on electric trucks: connections, electrolyte or charge level, and no damage; cover and restraint in place
Key on (operational check, engine or motor running):
- Service brake: firm pedal and normal stopping distance, with no sponginess
- Parking brake: holds the truck on a grade
- Steering: responds without excessive free play
- Drive control: smooth forward and reverse
- Hoist and lower: raises and lowers smoothly, with no drift
- Tilt control: forward and back function correctly and hold
- Attachment controls (if fitted) operate correctly
- Horn, lights, gauges, and the hour meter
- Back-up alarm and warning lights (if equipped)
- Any unusual noise or vibration, reported immediately
What happens if you find a defect?
Any condition that adversely affects safety takes the truck out of service until it is repaired. 1910.178(q)(7) forbids placing a truck in service when the examination reveals such a condition, and 1910.178(p)(1) requires that a truck found in need of repair, defective, or in any way unsafe be taken out of service until it has been restored to safe operating condition. A tagged brake or a leaking hydraulic line is not a "watch it this shift" item. It is a park-it item.
A New Jersey FACE investigation shows the cost of ignoring that. In NJ FACE report 98-NJ-038-01, a 42-year-old worker at a food distribution warehouse, who had no forklift training and had been told not to drive, took a propane counterbalance truck, drove it too fast, tipped it turning a corner, tried to jump clear, and was crushed by the rollover cage. The OSHA compliance officer investigating the incident determined that the truck's emergency brake was not working properly. A brake that does not work is exactly the condition a pre-shift examination exists to catch, and 1910.178(q)(7) and 1910.178(p)(1) exist to keep that truck off the floor. The transferable point is that the daily check only protects anyone if a failed item actually removes the truck from service.
How often is the examination required, and who signs it?
The examination is required before the truck is placed in service and at least daily, and after each shift where trucks are used around the clock. That frequency comes directly from 1910.178(q)(7). In practice that means a documented check at the start of each shift the truck runs, so a defect that develops on nights is caught before days, and the other way around.
Document who did the check and when, and record defects and their correction. The standard's language about examining the truck and reporting and correcting defects only becomes auditable if there is a dated record with a name on it. An undated, unsigned checklist proves nothing after an incident, and it does nothing to prove the defective truck was ever pulled from service.
