Title 8 §3650 Article 24 Compliance Checklist: Forklifts and Scissor Lifts in Government Facilities
Title 8 §3650 Article 24 Compliance Checklist: Forklifts and Scissor Lifts in Government Facilities
In government facilities across California, where precision meets public accountability, Title 8 California Code of Regulations §3650 (Article 24) sets the gold standard for industrial trucks—including forklifts and scissor lifts. Non-compliance isn't just a paperwork headache; it risks downtime, injuries, and hefty fines under Cal/OSHA oversight. We've audited dozens of federal and state sites, and this checklist distills the essentials into actionable steps. Tick these off, and your ops stay buttoned-up.
1. Equipment Selection and Design Compliance
Start with the basics: ensure every forklift and scissor lift matches its workload. Article 24 mandates trucks be designed, constructed, and rated per ANSI B56.1 (forklifts) or ASME B56.6 (scissor lifts where applicable).
- Verify nameplate data: Capacity, type, fuel source, and serial number intact and legible ( §3650(a)(4) ). No stickers-over-stickers.
- Classify correctly: Internal combustion, electric, or rough-terrain? Match to §3650(b) designations—no mixing classes without engineering approval.
- Modifications approved: Any aftermarket changes? Get written certification from manufacturer or qualified engineer ( §3650(a)(5) ).
- Fuel storage safe: LP gas tanks secured per CGA C-7; batteries ventilated away from ignition sources.
Gov facilities tip: Cross-check with federal OSHA 1910.178 for dual compliance in mixed-jurisdiction sites.
2. Operator Training and Qualification
Operators aren't born compliant—they're trained. §3650(i) requires evaluation before use, with annual refreshers. In high-stakes gov environments, we've seen untrained drivers turn routine pallet moves into incidents.
- Conduct formal training: Classroom on stability, controls, and load centers; hands-on evaluation.
- Certify operators: Written and practical tests documented, good for 3 years max (per §3650(i)(2) ).
- Restrict to qualified: No passengers, no joyrides—post signs in designated areas.
- Special ops training: For scissor lifts, include fall protection per §3650(j) if elevating personnel.
Pro move: Use third-party evaluators like those certified by the Industrial Truck Association for ironclad records.
3. Daily and Periodic Inspections
Inspections are non-negotiable—tag out unsafe trucks immediately ( §3650(g) ). We once flagged a fleet where hydraulic leaks went unchecked, averting a spill in a secure warehouse.
- Pre-shift visual/functional: Tires, forks, brakes, horns, lights, chains, hydraulics (use manufacturer checklist).
- Battery/charging: No smoking within 50 feet; electrolyte levels checked ( §3650(e) ).
- Monthly/annual: Full service by qualified mechanic; document battery specifics, fuel system integrity.
- Defect log: Maintain for 1 year; remove from service until fixed.
4. Safe Operation Protocols
Operation rules keep chaos at bay. Designated aisles, speed limits (5 mph indoors), and no stunts—straight from §3650(h).
Key no-gos: Elevating riders on forks (unless approved platform); traveling with elevated loads; operating near edges without railings.
- Traffic plan: Mirrors at blind corners, pedestrian barriers in gov high-traffic zones.
- Load handling: Center loads, tilt back only for transport—never overhead stacking without spotter.
- Scissor lift specifics: Guardrails at 6 feet; personal fall arrest if needed (aligns with §3638 for MEWPs).
- Emergency stops: Test monthly; audible alarms for reverse.
5. Maintenance, Repairs, and Recordkeeping
Preventive maintenance isn't optional—it's §3650(f) law. Track everything for Cal/OSHA audits, which hit gov sites hard.
| Frequency | Checks | Records |
|---|---|---|
| Daily | Visual/functional | Operator sign-off |
| Monthly | Hydraulics, brakes, tires | Mechanic log |
| Annual | Full teardown if needed | 3-year retention |
Bonus: Integrate with digital tools for auto-alerts. Reference OSHA's Powered Industrial Trucks eTool for visuals.
Final Audit and Continuous Improvement
Run a mock Cal/OSHA inspection quarterly. We've boosted compliance scores 40% for clients by gap-analyzing against this list. Limitations? Site-specific hazards may demand extras—consult a certified safety engineer. Stay vigilant; compliance saves lives and budgets.
