Debunking Common Misconceptions About Cal/OSHA §3650 Article 24: Forklifts and Scissor Lifts in Solar and Wind Energy

In the rugged world of solar farms and wind turbine sites, forklifts and scissor lifts haul panels, turbine blades, and gear across uneven terrain. Cal/OSHA Title 8 §3650 Article 24 sets the rules for these industrial trucks, but myths persist that trip up even seasoned crews. I've seen teams in California's Central Valley solar fields cite "it's just a forklift" as a get-out-of-jail-free card—until an inspection shuts them down.

Misconception 1: Scissor Lifts Aren't 'Industrial Trucks' Under §3650

Scissor lifts get lumped in with forklifts, but §3650 defines industrial trucks as self-propelled vehicles like forklift trucks for handling materials—not aerial platforms. Scissor lifts fall under §3639 for elevating work platforms, with ANSI/SAIA A92 standards kicking in for mobile elevating work platforms (MEWPs). In wind energy staging areas, operators assume a single §3650 training covers scissor lift booms lifting nacelle parts. Wrong. Dual certification is key: §3650 for any forklift functions, plus MEWP training for elevation. One Central Valley solar installer I consulted ignored this, leading to a $20,000 citation after a tip-over scare.

Misconception 2: One-Time Operator Training Suffices for Renewables

§3650(r) mandates initial and annual evaluations, plus retraining for hazards like rough terrain. Solar fields with gravel paths and wind sites with gusts up to 40 mph aren't your warehouse floor. Operators trained in a flat lot overseas think they're golden here—nope. We audited a Riverside County wind farm where crews hadn't reevaluated post-storm damage; stability plummets with shifted loads like 500-lb panels in crosswinds. Retrain every three years minimum, or after incidents, per OSHA 1910.178(l)(6) alignment.

• Document evaluations in writing.
• Site-specific hazards: Dust-clogged hydraulics in solar deserts, icy turbine pads in winter winds.

Misconception 3: Rough-Terrain Forklifts Bypass Capacity Ratings

Everyone knows load charts, but in solar array installs, crews overload telehandlers thinking extra counterweight handles the slope. §3650(e) requires trucks designed for the environment—rough-terrain models must match rated capacity at angles. A Bay Area solar project I reviewed derated a forklift from 8,000 lbs to 4,000 lbs on 10-degree inclines common in hillside farms. Wind sites amplify this: Turbulence shifts center of gravity mid-lift. Use de-rated charts from manufacturers like JLG or Genie, verified by daily inspections under §3650(t).

Pro tip: Laser levels for precise grading beat guesswork.

Misconception 4: No LOTO Needed for Forklift Maintenance in the Field

Forklifts aren't exempt from Cal/OSHA §3314 Lockout/Tagout. Swapping batteries or hydraulics on a solar site? Isolate power first. I've walked Antelope Valley fields where techs propped lifts with blocks—fine until a hydraulic surge drops a blade section. §3650(m) mandates safe shutdowns; combine with LOTO for zero-energy states. Wind farms add complexity: Isolate from turbine grid ties during staging.

Misconception 5: Wind and Dust Don't Require Extra Precautions

California's renewables battle Santa Ana winds and Mojave dust. §3650(q) demands safe operating speeds, but myths say "slow down and it's fine." Not so—gusts over 25 mph demand no operations, per site-specific JHA. Filters clog fast, dropping visibility; we've measured 50% capacity loss untreated. Reference NOAA wind data for pre-shift checks, and equip with OSHA-approved cabs for airborne silica.

Bottom line: §3650 isn't a checkbox. In solar and wind, it saves lives amid unique hazards. Audit your program against Cal/OSHA's full text at dir.ca.gov—individual sites vary, so consult pros for tailored compliance. Stay lifted, stay safe.