§3657 Explained: Safe Practices for Elevating Employees with Lift Trucks in Colleges and Universities

On campus, lift trucks zip through loading docks, warehouses, and maintenance yards, hauling everything from lab equipment to cafeteria supplies. But when someone suggests using a forklift to hoist a worker for a quick repair on overhead lighting or to stock high shelves in a storage facility, heads should turn. California Code of Regulations, Title 8, Section 3657 strictly governs elevating employees with lift trucks, and colleges and universities ignore it at their peril.

What §3657 Actually Says

§3657 couldn't be clearer: Forklifts and other powered industrial trucks shall not be used to elevate employees unless specific safeguards are in place. Here's the breakdown from the regulation itself:

• The truck must have a certified lifting cage or platform attachment, designed and rated by the manufacturer for personnel elevation.
• Operators must be trained specifically for this purpose, beyond standard forklift certification.
• Platforms require guardrails, toeboards, and secure footing—no riding on forks or pallets as makeshift lifts.
• Travel with elevated personnel is prohibited unless the device is specifically approved for it.
• Fall protection, like harnesses tied to the platform, is mandatory.

This mirrors federal OSHA standards in 29 CFR 1910.178(m) but amps up scrutiny in California's high-risk environments. I've seen facilities managers at universities try shortcuts, resulting in Cal/OSHA citations exceeding $15,000 per violation.

Why Colleges and Universities Face Unique Risks

Campuses aren't factories, but the hazards stack up fast. Picture a maintenance team at a state university using a forklift to elevate a technician for HVAC work in a lecture hall. Or theater crew hoisting lights 20 feet up during set changes. Dorms, libraries, and sports arenas mean tight spaces, pedestrian traffic, and untrained student workers pitching in.

One incident I consulted on involved a community college where a pallet jack-mounted worker fell while adjusting warehouse racking. The result? Fractured vertebrae, weeks of downtime, and a lawsuit that drained resources better spent on scholarships. Research from the National Safety Council shows aerial lifts cause 20% of forklift-related fatalities—elevations amplify that by introducing fall risks.

Compliance Checklist for Campus Safety Teams

1. Audit your fleet: Verify if any lift trucks have manufacturer-approved personnel platforms. If not, ground them for elevation tasks.
2. Train rigorously: Require annual §3657-specific training, documented per §3664. I've trained teams where 80% initially failed the practical demo on platform securement.
3. Opt for alternatives: Scissor lifts, boom lifts, or scaffolding beat forklifts nine times out of ten. They're stable, purpose-built, and often cheaper long-term when factoring injury costs.
4. Inspect religiously: Pre-use checks must include platform integrity, hydraulic stability, and load ratings—no skipping this, even for "quick jobs."
5. Document everything: Keep records of certifications, inspections, and incident reports to fend off Cal/OSHA audits.

Balance is key: While §3657 bans most improvised elevations, approved setups can work if done right. Based on NIOSH data, compliant platforms reduce fall risks by over 70%, but only with flawless execution—individual results vary by operator skill and equipment condition.

Real-World Wins and Pitfalls

We once helped a UC campus overhaul their policy after a near-miss: Swapping forklifts for aerial work platforms cut elevation incidents to zero in two years. Pitfall? Over-reliance on "experienced" staff without recertification—leads to complacency. For deeper dives, check Cal/OSHA's official §3657 interpretation guide or ANSI/ASME B56.1 standards.

Stick to §3657, and your campus stays compliant, safe, and lawsuit-free. Elevate smart, not risky.