Technical Information Bulletin 

U.S. Department of Labor

Occupational Safety and Health Administration

 Inspection of Suspension-Type Highway Trailers Prior to

 Loading and Unloading with Powered Industrial Trucks

Purpose

The purpose of this Technical Information Bulletin is:

1. To alert employers and employees regarding the

need to inspect suspension-type highway trailers

to ensure that the trailers will support powered

industrial trucks during loading and unloading operations; and

2. To provide a list of inspection check points for

employers and employees to use in order to determine whether it is safe to use powered industrial trucks for loading and unloading such trailers.

Background

The Directorate of Safety Standards Programs

brought to the attention of the Directorate of Technical Support the fact that workers engaged in the

loading or unloading of suspension-type highway

trailers may be at an increased risk of injury due to

the inability of damaged trailers to support the weight

of the powered industrial truck used to load or unload the trailer. These trailer designs present hazards not encountered with trailers of older, traditional

designs. OSHA has received several reports of trailer

collapse accidents in situations in which the employees attempted to enter a trailer and to load or unload

that trailer with a powered industrial truck.

Technical Information

There are three trailer designs of primary concern: (1) the fiberglass-reinforced panel; (2) the sheet

and post; and (3) the plate trailer.

These trailers are designed and manufactured

in a manner similar to a suspension bridge with the

weight of the floor and the load supported by the

walls, which hang from the roof of the trailer. The

roof of the trailer, in turn, is supported at the four

corners of the trailer. The undercarriage of the trailer

consists of a series of parallel rails that run laterally

across the trailer. The rails are attached to the remainder of the trailer by a group of four to six rivets

at each end of the rail.

These trailer designs were developed to

decrease the weight of the trailer, thereby increasing the allowable weight of the load that the trailer

can carry. The trailers can be identified by the

absence of an I beam running fore and aft under

the full length of the trailer floors.

Recommendations

Suspension-type trailers should be inspected

before they are loaded or unloaded with a powered

industrial truck. Any of the following types of damage to the trailer should be identified and docu-

 TIB 00-07-31

 This TIB is not a new standard or regulation

 and it creates no new legal obligations. It is

 advisory in nature, informational in content,

 and is intended to assist employers in providing

 a safe and healthful workplace.

 For a more detailed description of the nature

 and effect of Technical Information Bulletins,

 see the Important Information box at the end of

 this bulletin.
mented. A determination should be made whether

the trailer can or cannot be loaded or unloaded safely

prior to using a powered industrial truck. In the event

that the trailer cannot be loaded or unloaded safely

with a powered industrial truck, an alternative means

of loading or unloading must be used. If the integrity of the trailer cannot be assured and no other reasonable means exists to complete the operation, the

trailer should be taken out of service.

Inspection Check Points

1. Examine the rear impact guard (the ICC bar).

Damage to this guard may indicate the presence

of other damage to the trailer, thereby decreasing

the trailer’s ability to support the weight of the

load and the powered industrial truck used to load

or unload the trailer. Also, when a trailer restraint

is used, a damaged ICC bar may prevent the trailer

restraint from effectively engaging, thus permitting the trailer to roll away from the dock.

2. Examine the front landing gear of the trailer. Damage to this part of the trailer could cause the trailer

landing gear and the front of the trailer to collapse

when the weight of the powered industrial truck

is added to the weight of the trailer and the load

being supported by the front landing gear.

3. Examine the cross members of the undercarriage

for missing pieces, excessive corrosion, or permanent deformation. For example, deformation

of the cross members caused by missing rivets at

the ends of the cross members can indicate damage to the trailer floor. In such cases, the trailer

may not support the weight of a powered industrial truck.

4. Examine the exterior sides of the trailer for tears

or cuts of the skin that exceed 21 inches or that

would affect more than one trailer side post.

5. Look for missing rivets, particularly near the bottom of the trailer. Damaged or missing rivets may

indicate that the ability of the undercarriage to

support the weight of the load and the powered

industrial truck used to move the load has been

compromised.

6. Look at the rear doors of the trailer. Damage to

the rear doors of the trailer may indicate that the

trailer was struck in the rear, thereby possibly causing other damage to the trailer and possibly creating a hazard when opening and closing doors.

7. Look at the hinges that support the rear doors.

Damage to these hinges could indicate damage to

the floor of the trailer or a shifting of the load during transit. Damage to the hinges could include

broken or missing rivets, damage to other means

of hinge attachment (e.g., welds), broken hinges,

or missing hinge pins. Damage of this nature may

compromise the ability of the trailer to support

the weight of the powered industrial truck.

8. Examine the interior walls of the trailer for breaks,

tears or other damage, particularly within two feet

of the floor of the trailer. Tears or cuts in more

than one post could adversely affect the ability of

the trailer to support the weight of the load and

the powered industrial truck being used to move

the load. On sheet and post trailers, vertical posts

(most commonly on 16" - 24" centers) should not

be severed. A vertical post that is severed presents a hazard.

9. Look at the roof of the trailer. Damage to the roof

of the trailer may indicate the mishandling of the

load when the trailer was being loaded and unloaded. Such mishandling could produce other

structural damage to the trailer that may be visually apparent. Damage to the roof structure of the

trailer could allow trailer walls to fold in or out

resulting in a floor collapse.

10. Examine the floor of the trailer; look for imperfections or abnormalities, including an excessively

wavy appearance of the laminated floor, delamination of the floor, cracks, and/or missing pieces

of flooring. When unloading the trailer, the powered industrial truck operator should continually

check the condition of the newly exposed portion

of the floor as the unloading proceeds. The powered industrial truck operator also should check

for water stains on the floor, which may indicate

that the floor has been damaged by water [see 29

CFR 1910.178 (m)(7)].

 The existence of any one, or even several,

of the above listed deficiencies does not necessarily

render the trailer unsafe to enter with a powered in-
Important Information on the

 Nature and Effect of Technical

 Information Bulletins

OSHA’s Directorate of Technical Support

(DTS) issues Technical Information Bulletins

(TIBs) to provide information about occupational

hazards and /or to provide information about

noteworthy, innovative, or specialized procedures,

practices and research that relate to occupational

safety and health. DTS selects topics for TIBs

from recognized scientific, industrial hygiene,

labor, industry, engineering, and/or medical

sources.

The Occupational Safety and Health Act

requires employers to comply with hazard-specific

safety and health standards. In addition, employers

must provide their employees with a workplace

free from recognized hazards likely to cause death

or serious physical harm under Section 5(a)(1), the

General Duty Clause of the Act. Employers can be

cited for violating the General Duty Clause if there

is a recognized hazard and they do not take appropriate steps to prevent or abate the hazard. However, the failure to implement TIB recommendations is not, in itself, a violation of the General

Duty Clause. Citations can only be based on

standards, regulations, and the General Duty

Clause.

dustrial truck. However, such deficiencies are indications of possible serious damage, and the employer

will need to exercise professional judgement to determine whether it is safe to use a powered industrial truck for loading and unloading the trailer.

Further information about this bulletin may

be obtained by contacting OSHA’s Directorate of

Technical Support at 202-693-2300

 *