Debunking Common Misconceptions About Cal/OSHA §3650 Article 24: Industrial Trucks, Forklifts, and Scissor Lifts

California's Title 8, §3650 under Article 24 sets the gold standard for industrial trucks—including forklifts and related powered equipment. Yet, in safety management services for mid-sized manufacturers and warehouses, we routinely encounter teams misapplying these rules. These slip-ups don't just risk citations; they invite real hazards. Let's cut through the fog with five prevalent myths, backed by the reg itself.

Misconception 1: All Forklift Operators Need Identical Training

One persistent error? Assuming a single forklift certification covers every truck type. §3650 mandates training tailored to the specific industrial truck—think counterbalanced sit-downs versus order pickers or rough-terrain models. We've audited sites where operators hopped between truck classes without retraining, leading to near-misses.

Cal/OSHA requires operators to demonstrate proficiency on their equipment under §3650(t). Generic online courses? They fall short if not site- and truck-specific. Pro tip: Document evaluations every three years, or sooner if incidents occur.

Misconception 2: Scissor Lifts Fall Outside Article 24 Scope

Scissor lifts spark confusion—they're mobile elevating work platforms (MEWPs), but when powered and truck-mounted, §3650 applies alongside §3638 for aerial devices. Many management teams treat them as 'just ladders on wheels,' skipping truck-specific mods like stability checks.

Reality check: §3650(g) demands approved trucks only, and scissor lifts must meet design standards. In one facility we consulted, ignoring this led to a tip-over during uneven loading. Cross-reference with ANSI A92.6 for full compliance—both regs reinforce each other.

Misconception 3: Daily Inspections Are Optional If No Issues Are Obvious

'It runs fine, so why bother?' That's a recipe for downtime. §3650(q) requires daily pre-use inspections by operators, with designated lists covering tires, hydraulics, horns, and more. Skipping them? Expect fines up to $25,000 per violation.

• Visual checks: Leaks, damage.
• Functional tests: Brakes, steering.
• Record keeping: Tag out defective units immediately.

We've seen 'inspection fatigue' in high-volume ops; combat it with laminated checklists and digital logs for accountability.

Misconception 4: Fueling and Charging Can Happen Anywhere, Anytime

No smoking nearby? Good start, but §3650(u) and (v) dictate designated areas for LP gas, battery charging, and fueling—ventilated, away from ignition sources, with spill containment. A common oversight in busy distribution centers.

LP trucks need flashback arrestors; electrics require PPE during watering. One client avoided disaster after we flagged improper battery bays—acid fumes had built up unnoticed. Balance efficiency with these rules to prevent fires or exposures.

Misconception 5: Only OSHA Matters; Cal/OSHA §3650 Is Identical

Federal OSHA 1910.178 is similar, but California's §3650 amps up specifics like seismic bracing for LP tanks (§3650(r)(10)) and operator-up only travel (§3650(s)). Ignoring state variances in safety management services invites double trouble during audits.

Cal/OSHA's enforcement is rigorous—over 1,200 forklift citations yearly per DIR data. Stay sharp by prioritizing Title 8 over federal baselines.

Armed with these clarifications, revisit your industrial truck program. Reference the full §3650 text at dir.ca.gov/title8/3650.html, and consider third-party audits for blind spots. Solid compliance isn't just regulatory—it's your edge in zero-incident operations.