Compliance Cheat Sheet: How to Comply with Powered Mobile Equipment Signaller Requirements
Unsafe operation of forklifts and other powered mobile equipment (PME) is a leading cause of workplace fatalities and serious injuries. Although there are no equivalent Canadian studies, OSHA estimates that 7 out of 10 PME incidents in the U.S. are preventable. The vast majority of these take place when the equipment is in motion. Common scenario: Operators who can’t see where they’re going drive off edges or graded surfaces or into machinery, fixtures and, of course, other workers. To prevent this, OHS regulations of all jurisdictions require use of signallers to direct PME operators. Here are the 8 things you must know to comply with these rules. (Go to the OHSI website to find an “Around the Provinces” chart summarizing the signaller rules in your own jurisdiction.)
1. What a Signaller Does & Doesn’t Do
This article is about workers designated to provide hand or, where visibility is impaired, radio or telecommunication signals to persons operating PME who don’t have a full and clear view. In most jurisdictions, including FED, BC, NB, NL, NS, ON, YK, this worker is known as a “signaller” (and that’s the term we’ll use in the article.) In MB and QC, this worker is called a “signal person” and in AB a “designated signaller.” NT, NU and SK just say that a worker must give signals without assigning a specific title.
Don’t confuse “signaller” with “designated signaller” or “traffic control person” entrusted with directing traffic in parking lots, roads, highways and other sites where pedestrians, equipment and vehicles of all kinds circulate as part of a more elaborate traffic control plan. The “signaller” function is much more limited.
Final Note: This analysis covers use signallers for movement of PME and doesn’t address the different requirements for using signallers to direct operators of hoists and cranes.
2. When Signallers Are Required
Use of signallers is an administrative/work control that must be used: i. when PME operators have an obstructed or partially obstructed view of the load or intended path of travel; and ii. engineering controls like audible warning devices, systems that stop the equipment automatically upon sensing an object or worker and automated traffic control systems aren’t reasonably practicable or effective under the conditions. Some jurisdictions also require signallers to be used for specific PME operations or maneuvers that pose a high degree of danger, including:
- Use of rear-dumping PME to discharge loads at the edge of a sudden drop in grade levels that may cause the equipment to tip, unless a bumping block is used to prevent tipping (FED);
- At a construction site where PME is operated in reverse or in a way that may endanger the operator or another worker (MB, QC); and
- Use of PME at any site where the equipment or any of its parts may come within 3 meters of an overhead electrical line (MB).
3. Who Can Serve as a Signaller
Whether spelled out or implied, the worker designated to act as signaller must be “competent,” i.e., familiar with the OHS regulatory requirements that apply and qualified because of knowledge, training and experience to perform signalling duties, specifically:
- The use of hand signals to direct the PME operator;
- The use of the other equipment that may be required to direct the operator when visibility issues or conditions render hand signals ineffective;
- Assessing whether it’s safe for the equipment to proceed into the travel area.
|Note: In Québec, signallers are more like what most other jurisdictions call “traffic control persons” and require extensive training if they’re designated to serve as a “site traffic control” person at a construction project.|
4. What Signallers Are Required to Do
While the rules vary slightly by jurisdiction, signallers are basically required to:
- Station themselves in a spot that’s safe, out of the way and in continuous view of the operator;
- Ensure they have a clear and unobstructed view of the path of travel and area into which the PME will move;
- Verify that it’s safe to proceed before giving the signal to go;
- Not perform any other duties while acting as signaller.
5. What Equipment Signallers Must Use
Safety equipment requirements for signallers are less stringent than for traffic controllers. Signallers basically just have to make themselves visible and deliver clear hand signals without need for wands, flashlights, paddles or other special equipment. However, visibility-enhancing or non-visual communication equipment may become necessary if normal hand signals would be ineffective and signallers must be prepared to use it.
6. What PPE Signallers Must Use
Unlike traffic control persons, high-visibility apparel isn’t expressly required to perform PME signalling duties. Exceptions: High-visibility apparel is required for signallers at construction projects in Ontario and Québec (in the latter case, if the signaller is the site signal person), and at all sites in Alberta. And, of course, high-visibility apparel is required for any worker in construction zones or other locations where they’d be exposed to danger because people may not be able to see them.
7. What Employers Must Do
Ultimate responsibility for safe operation of PME at the site falls to the employer (or the constructor or prime contractor if the workplace is a construction project.) In the context using signallers to direct PME operations, employers/constructors must:
- Ensure signallers are used when the OHS regulations require;
- Designate competent workers to serve as signallers;
- Ensure that multiple signallers are available at the site in case the signaller needs help;
- Ensure that safe work procedures and a well understood code of signals is in place;
- Ensure that signallers receive the necessary training, instruction and supervision; and
- Furnish the equipment, PPE and high-visibility apparel required for signalling operations.
8. What PME Operators Must Do
The PME operator must:
- Understand and agree with the signaller on the code of signals to be used;
- Refrain from starting the equipment until getting the go-ahead from the signaller;
- Keep his/her eyes on the signaller;
- Obey all of the signals; and
- Treat a missed or unclear signal as a “STOP” signal.