OSHA Standards for Full Pallet In Full Pallet Out Facilities
Warehouse operators who specialize in full pallet in/full pallet out workflows avoid some of the OSHA violations that tend to trouble traditional distribution centers. The risks simply aren’t the same as in a traditional warehouse.
There are a few reasons for this. For one thing, virtually everyone who enters the aisles in a full pallet in/full pallet out operation does so on a forklift. For another, order packers in this environment typically don’t have to worry about ergonomic injuries. In a true full pallet in/full pallet out facility, there are no order packers as such.
In fact, some would argue that removing manual material handling from the facility reduces the number of OSHA standards operators have to worry about.
That might be a bit hasty. The risks at a full pallet in/out warehouse — and the associated workplace safety rules — aren’t “less” when staff members only handle full pallets. They’re just different.
We’ve written a lot about OSHA standards in the traditional warehouse (for instance, here, here, and here). But we haven’t addressed the issue in a full-pallet-only scenario … until now. So here are the top enforceable safety rules from the Occupational Safety and Health Administration that full pallet-focused warehouse operators need to know.
Defining Full Pallet In/Full Pallet Out and Crossdocking
Before we get into the details, it’s important to define our terms. Logistics professionals sometimes mean different things when they bring up a full pallet in/full pallet out operation. To add to the confusion, full pallet terminology is closely related to other industry jargon, particularly “crossdocking.”
Here’s what we mean by each term:
Full Pallet In/Full Pallet Out Warehousing: As the name implies, a full pallet in/out facility only deals in full pallets. Compare this to a traditional warehouse or distribution center, where staff may receive full pallets and break them down into individual orders.
Many logistics centers receive full pallets, break them down, build them back into mixed pallet loads, and send full pallets out again. However, for our purposes here, we’re concerned with material storage and handling facilities that strictly receive full pallets, store full pallets, and ship full pallets back out again — no consolidation or de-consolidation at the parcel level.
Crossdocking is related to full pallet in/full pallet out logistics; often, the latter is an example of the former. But crossdocking refers to any flow of goods in which a shipment goes straight from the source (a manufacturer or importer, for instance) to the customer without much, if any, time in storage.
Note that at the truckload level, many full pallet in/out facilities do consolidate shipments. Combining less-than-load (LTL) shipments into a single full truck load (FTL) can save a fortune in shipping costs. In fact, shipment consolidation at the trailer level is one of the great advantages provided by full pallet in/full pallet out warehouses and crossdockers alike.
Three Areas of OSHA Standards for Full Pallet Workflows
Authorities in charge of safety at a full pallet in/full pallet out facility should focus on three particular areas of OSHA guidance: working with forklifts, working with pallets more generally, and working at the loading dock.
Here are some of the most important OSHA safety standards in each of these areas:
OSHA Standards for Forklift Safety
Any facility that only handles full pallet loads must operate a busy forklift fleet, creating potential hazards along the way. According to the most recent analysis from the National Institute for Occupational Safety and Health (NIOSH), which looked at forklift-related deaths at U.S. workplaces between 1980 and 1994, the most dangerous forklift accidents were the following:
- Forklifts overturning, which comprised 22 percent of the total fatalities in the study period.
- Forklifts striking pedestrian workers, which followed with 20 percent of the fatalities.
- Forklifts running over or falling on workers, crushing them, which accounted for 16 percent of the victims.
- Falling from a forklift, presumably raised forks or the roof, which made up only 9 percent of the fatal accidents NIOSH studied.
In the interest of preventing injuries like those noted above, OSHA provides legal standards, best practices, and other forms of guidance. The Code of Federal Regulations standard covering OSHA’s rules for safe forklift operation can be found in 29 CFR 1910.178.
This standard addresses everything from the varying classes of forklifts to where they can operate to truck operation standards.
OSHA Rules for Working with Pallets
Particular OSHA regulations on handling fully loaded pallets are less clear than those covering forklift operation. In fact, some of Administration’s most important safety rules for handling pallet loads can be found in 29 CFR 1910.178, the standard on forklift operation. These include the provisions located in standard 1910.178(o), which covers loading trucks. For instance:
- 178(o)(1) states that “only stable or safely arranged loads shall be handled,” and that “caution shall be exercised when handling off-center loads which cannot be centered.” If a pallet load shifts or becomes unstable, then, forklift operators must be aware and address the challenge either through repacking the pallet or by operating with extreme caution.
- 178(o)(2) states that “only loads within the rated capacity of the truck shall be handled.” Most successful full pallet in/full pallet out operations provide weight designations (among other load data) on a license plate or other data carrier posted on each pallet. All operators should verify that loads are within the truck’s tolerance before attempting to lift.
- 178(o)(3) states that “the long or high (including multiple-tiered) loads which may affect capacity shall be adjusted.” Perhaps the safest way to adhere to this rule is to avoid handling stacked loaded pallets in the first place.
In addition to rules on handling loaded pallets with forklifts, some OSHA standards place limits on where and how high pallets may be stacked, both alone and within racking systems. For instance, 29 CFR 1910.176(b) tells us that “storage of material shall not create a hazard.”
This standard is written broadly enough to allow inspectors to cite facilities anytime they see a racking system or pallet stack that looks at all unsafe. Therefore, the best practice is to adhere to racking limits and avoid stacking pallets outside of racks designed for the purpose.
Another important rule comes from standard 1910.159(c)(10), which is about sprinkler systems. This rule tells us that “the minimum vertical clearance between sprinklers and material below shall be 18 inches.”
When designing or altering pallet racking systems, then, warehouse operators must ensure that top-level pallets don’t approach within 18 inches of sprinkler units in the ceiling.
OSHA Guidance for Loading and Unloading Trucks
According to OSHA’s general guide to safety while loading and unloading trucks, the now-familiar standards on Powered Industrial Trucks (1910.178) are the most-cited at the loading dock. A thorough study of the standards in 1910.178 is crucial for any safety manager at a full pallet in/full pallet out facility.
In addition to the standards on operating forklifts, the following OSHA rules apply to work loading and unloading trucks at the dock:
- 26(a) requires employers to ensure that any dockboards used to bridge the gap between the dock and a trailer are “capable of supporting the maximum intended load.” Again, this requires careful tracking and transmission of the total weight of loaded pallets as well as the trucks that carry them.
- 26(b) requires all use of dockboards after January 17, 2017 to be “designed, constructed and maintained to prevent transfer vehicles from running off the dockboard edge.”
- Some facilities may use Dock Ramps to access the yard or a trailer, rather than going straight from the dock, via dockboard. In these instances, the same safety curbs required for dockboards will create a much safer environment. Dock Ramps and Yard Ramps from Solus Group feature 8-inch steel safety curbs at either edge, preventing forklifts from falls.
- 26(c) states that dockboards must be “secured by anchoring them in place or using equipment or devices that prevent the dockboard from moving out of a safe position.” Shifting dock boards create a clear risk of forklift accidents.
- 26(2) states that “measures, such as wheel chocks or sand shoes” must be used to “prevent the transport vehicle...from moving while employees are on the dockboard.” Shifting trucks are another common cause of serious forklift accidents at the dock.
The above OSHA standards are not the only ones operators of full pallet in/full pallet out facilities must adhere to. Far from it. However, they do provide an introduction to the problem of safety at this particular style of warehouse.
Finally, we’d like to mention one set of OSHA standards that makes a major difference at virtually any warehouse or distribution center: 29 CFR 1910.147, on the control of hazardous energy, otherwise known as the standards on lockout/tagout procedures.
Wherever employees use heavy equipment, whether that’s a forklift or another material handling system, lockout/tagout procedures can prevent many serious injuries. This standard can even save lives. While that’s true in many workplaces, it’s particularly important for full pallet in/full pallet out facilities.
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