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Safe Pallet and Material Handling Solutions
By ADELE L. ABRAMS, ESQ., CMSP
Pallet safety best practices for OSHA Compliance
During inspection of pallet manufacturing and warehousing facilities, the Occupational Safety & Health Administration (OSHA) focuses on many potential common safety and health hazards, including noise, wood dust, and machine guarding. But another area that can be a source of citations – with maximum penalties now set at $129,336 – is materials storage and handling. In a 2015 warehouse accident, where three workers were hospitalized, 30 pallets holding glass drinks collapsed on the employees, the company was fined over $100,000 and was placed in OSHA’s Severe Violator Enforcement Program.
Employers can face citations alleging that empty pallets are stacked too high, or are unstable, or that forklift operators are not handling them safely as they are moved around the plant or yard. If a pallet is damaged and spills materials on the floor, this can create a slip/trip/fall hazard for anyone in proximity. Lumber storage on site may also be subject to such scrutiny about storage arrangements, although that is covered under a different standard, 1910.265.
Of course, fire safety must be factored into the storage of pallets as well, and compliance with the revised 2018 International Fire Code (IFC) Section 2810, and 2017 edition of NFPA 1, Section 34.10.4, is a must. Fire safety codes for storage of pallets will be enforced both by OSHA (through its fire safety standards or the General Duty Clause) as well as by local building code enforcement officials. NWPCA has a compliance manual explaining the new consensus standards, available for free download.
OSHA, Material Handling and Pallet Safety
In terms of OSHA regulations on materials handling, the general industry rule is codified at 29 CFR 1910.176, but that rule (most recently amended in 1978) is quite vague in terms of providing any bright line specifications. In recent cases I have handled in the pallet sector, the inspector’s allegations basically came down to “it didn’t look safe to me” rather than benchmarking work practices against any particular standard. Those types of citations, absent an accident, are often relatively easy to have vacated or reduced to “other than serious.”
Section 1910.176 requires that when mechanical handling equipment is used to move pallet stacks or other materials, sufficient safe clearances must be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways should be kept clear and in good repair, with no obstructions across them to create a hazard, and permanent aisles should be appropriately marked.
OSHA also specifies in this standard: “Storage of material shall not create a hazard. Bags, containers, bundles, etc., stored in tiers shall be stacked, blocked, interlocked and limited in height so that they are stable and secure against sliding or collapse.” This is a broad obligation that requires an assessment regularly by the employer to ensure that a constantly changing work environment has not had unsafe conditions arise during a workshift. For those who might do work at or deliver to marine terminals, a separate but similar rule is in effect. Standard 1917.14 provides: “Cargo, pallets and other materials stored in tiers shall be stacked in such a manner as to provide stability against sliding and collapse.”
On construction sites, yet another set of standards applies to material storage and handling. Standard 1926.250(a), for example, specifies that “All materials stored in tiers shall be stacked, racked, blocked, interlocked or otherwise secured to prevent sliding, falling, or collapse.” It adds, in an interpretative letter from 2008, that shrink-wrapping or banding the bricks or blocks and stacking the palleted units in a manner that is adequate for flatbed shipping typically would qualify as “otherwise secured to prevent sliding, falling, or collapse.”