Letters

Electrical Apparatus, Jul 2004

Electrical Apparatus invites readers' comments, 250 words or less. Be sure to include your name, company, title, phone, city and slate or province (not e-mail).

Calling the grammar police

Editor:

Just out of curiosity, the cover of the May EA reads "An historic"? Is that proper? Shouldn't it be "a" historic?

Mark Bishop

AccuWind

Hamden, Connecticut

There isn't space here to quote that venerable grammar guide Fowler's Modern English Usage's comments about "a" and "an," but it would appear we both may be right, because it gets down to how one pronounces "historic."-Editor

Remembers Fran Powers

Editor:

The tribute to Francis J. Powers in the May EA was most deserving. He called on us with regularity, dignity, and decorum. It reminds me of how far back I go. . . .

Richard P. Reece

C.A. Industrial Publicity

Berlin Heights, Ohio

Says forklift article wrong

Editor:

As the executive director of the Industrial Truck Association, I would like to offer some comments on "The alarming gap in forklift safety" in the May EA. ITA is the non-profit trade association representing manufacturers of forklifts and their components and attachments. Several ITA members are also major users of forklifts. I am writing because it is important to correct certain statements in your article and to dispel any inference, which your article creates, that forklift manufacturers control the voluntary standards development process and have improperly ignored or obstructed the adoption of certain requirements in the areas of pedestrian safety and collision avoidance.

First, it is simply not true that the ANSI B56.1 Committee (the correct designation is "ASME B56 Subcommittee") "is controlled by the forklift industry association." The B56.1 Subcommittee has 34 members, only seven of which are ITA members and only six of which are manufacturers of forklifts. ASME standards are developed under procedures accredited as meeting the criteria of the American National Standards Institute, which includes the requirement for committee balance to ensure that the spectrum of competent and concerned interests has the opportunity to participate in the standards development process. The B56.1 Subcommittee that you reference has members representing users, safety consultants, insurance interests, OSHA, and the U.S. military. ITA has supported the balanced interest approach to standards development since the B56 project was initiated in 1948. The current chairman of the B56.1 committee is employed by Ford Motor Co., one of the largest users of forklifts. Thus to the extent that your article attributes the absence of forklift safety features to opposition by the manufacturers operating through their trade association, it is simply incorrect.

Second, you state that OSHA has done nothing since its creation to require safety devices on forklifts. Shortly after it was established by the Occupational Safety and Health Act of 1970, OSHA adopted regulations governing the design and use of industrial trucks. OSHA has amended these regulations several times since. Although the OSHA regulations reference the 1969 version of the B56.1 standard, OSHA enforces the current version of the B56.1 standard under the General Duty clause of the OSHA Act.

Third, you state that "forklift manufacturers have successfully lobbied for the exclusion of safety features," presumably intending to imply that forklift manufacturers lobbied OSHA not to require the safety features discussed in the article. You offer no support for this proposition and it is flatly untrue-OSHA has never even proposed those features and ITA and its members have never advanced any position to OSHA with respect to them. If you meant to imply that forklift manufacturers "lobbied" the B56.1 Subcommittee, this is a misleading and pejorative way to describe participation in the ASME process, which entails attendance at technical meetings and sharing engineering and safety perspectives in an effort to reach a consensus on safety issues. And any implication that ITA routinely opposes safety features simply ignores the record. ITA led the fight for the adoption of operator restraint systems and, just last year, successfully opposed a relaxation of the requirement that the systems be used. More broadly, the dozens of safety features called for by the B56.1 standard had the support of forklift manufacturers, who usually proposed the provisions calling for them.

Your article incorrectly casts the issue of across-the-board safety features as one of disagreement between manufacturers and users of forklifts as to how to protect pedestrians and avoid collisions. Although you state that forklift manufacturers' "viewpoint of what constitutes basic safety features often differs from that of users," your article also points out that a wide variety of "OSHA-recognized alarms" are available as optional equipment to any user who wishes to have them. You also point out that "when they are included as standard equipment by the manufacturer . . . the owner is expected to properly maintain them." Indeed, and sometimes ironically, your article cautions users to "look before you leap" because "backup alarms and other safety features . . . cannot be used in many situations." The article even gives several reasons why certain users may not want certain features. In short, the notion that forklift manufacturers are at odds with users because users uniformly want and need particular devices that are unavailable to them mischaracterizes the actual state of affairs.