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Forklift and material handling operations run through nearly every definable feature of work (DFOW) on a federal construction project — offloading deliveries, moving palletized material to laydown areas, staging stock at the workface, and feeding other trades. On USACE and NAVFAC contracts, this activity is governed primarily by EM 385-1-1 Chapter 14 (Material Handling, Storage, Disposal, and Conveyors) and paragraph 18-8.i, which requires all powered industrial trucks (PITs), forklifts, and telehandlers to meet ANSI/ITSDF B56.1 for design, inspection, and operation. Because forklifts routinely share ground with pedestrians and other equipment, this is one of the highest-frequency struck-by and tip-over exposures on site, and most districts expect a dedicated activity hazard analysis before the first pallet moves.
This AHA example is written for SSHOs, project engineers, and superintendents preparing submittals under EM 385-1-1, 15 March 2024, para 2-6: detailed job steps in work sequence, hazards for each step, controls written to the hierarchy in para 2-6.b, residual Risk Assessment Codes per step, and the equipment, training, inspection, and Competent Person blocks required by para 2-6.d(4). One edition note before you copy anything: solicitations issued on or after 15 March 2024 fall under the 2024 edition and its chapter-paragraph citation style, while contracts awarded under the 2014 edition keep the old numbering (e.g., 01.A.14) until completion — verify which edition your contract invokes before submitting.
The download follows the ENG Form 6206 layout so you can adapt it directly: header with overall RAC, job steps/hazards/controls/residual RAC table, equipment-training-inspection table, and the employee documentation sheet every involved worker signs before starting work (para 2-6.d(2)). Edit the steps to match your actual equipment and site — an activity hazard analysis copied without site-specific tailoring is the first thing a GDA rejects at the preparatory meeting.
Risk Assessment Code (RAC) Matrix — EM 385-1-1 (2024)
Severity ↓ / Probability →
Frequent
Likely
Occasional
Seldom
Unlikely
Catastrophic
E
E
H
H
M
Critical
E
H
H
M
L
Moderate
H
M
M
L
L
Negligible
M
L
L
L
L
E = Extremely High Risk · H = High Risk · M = Medium Risk · L = Low Risk
(per EM 385-1-1 2024, para 2-2.u/2-2.w and ENG Form 6206). Controls must reduce the
residual RAC to a level the approval authority accepts before work proceeds.
Sample AHA: Forklift and Material Handling Operations
On a phone, swipe the table sideways to see the controls
and residual RAC columns →
Overall RAC:M — Medium Risk (highest residual step RAC, per EM 385-1-1 2024 para 2-6.d(4)(f))
Mobilization: deliver forklift/telehandler to site and complete pre-use certification
Equipment arrives with undetected mechanical defects (brakes, steering, hydraulics) and is placed into service
Have a qualified mechanic inspect each machine before initial use and keep the one-time inspection report at the work site (18-5.a(2)).
Have the Competent Person inspect and document each machine on a checklist before it is placed into use, submit the checklist to the KO/COR, and correct all deficiencies before service (18-5.b(1)).
Give the KO or COR advance notice of equipment entering the site so the inspection can be observed and spot-checked (18-5.b(1)(d)).
Verify the rated capacity plate is posted on the vehicle, clearly visible to the operator, including alternate ratings for any removable counterweights (18-8.i(2)).
L
Truck rollover or crushing during offload of the forklift from the delivery trailer
Offload on firm, level ground using ramps rated for the machine weight, with the delivery driver's tie-downs released only after ramps are set.
Keep all personnel clear of the offload path and in a safe position while equipment is being unloaded (14-8.a(7)).
Inspect road and shoulder conditions in advance to confirm clearances and load capacities are safe for machine passage (18-5.c).
L
Site setup: establish travel routes, pedestrian separation, and laydown/storage areas
Pedestrian-forklift conflict in shared work zones
Lay out dedicated forklift travel routes and physically separate pedestrian walkways with barricades or delineators; keep stairways, passageways, gangways, and accessways free of materials and obstructions at all times (14-8.b(7)).
Post speed limits and require operators to travel at a speed that permits stopping in a safe manner (18-8.i(7)).
Restrict storage areas to authorized personnel only (14-8.b(8)).
Require high-visibility apparel for all personnel working near equipment travel routes (Ch 5 PPE).
M
Laydown area sited under or near overhead power lines
Do not store materials directly under power lines unless safe clearance is achieved, and document the situation in the AHA (14-8.b(4), Ch 11).
Plan telehandler boom travel paths so no part of the machine or load encroaches on minimum approach distances to energized lines.
L
Unstable ground, ramps, or dock transitions collapse under machine load
Verify ground bearing capacity and grade the laydown surface before staging heavy loads; evaluate handling needs by weight, size, distance, and path of movement (14-8.a(3)).
Properly secure dock boards and bridge plates before driving over them, drive over them carefully and slowly, and never exceed their rated capacities (18-8.i(6)).
L
Daily pre-shift inspection of forklift and storage systems
Operating a machine with failed brakes, horn, seat belt, or backup alarm
Operator checks the machine before each use — service brakes, parking brake, emergency stopping system, tires, horn, steering, seat belts, operating controls, backup alarms/lights, and fire extinguisher (18-5.a(4)).
Competent Person conducts and documents daily inspections of in-use equipment with date, inspector name, items inspected, and PASS/FAIL result (18-5.b(2)).
Tag out and remove from service any machine with a safety deficiency until repaired under the QP-run scheduled maintenance program (18-5.a(1)); keep records on site (18-5.a(5)).
L
Racking, pallets, or storage components fail under load
Inspect storage systems (racking, shelving, blocking) and packaging (containers, pallets) per the manufacturer's instructions; remove from service any component showing deterioration, leakage, or weakness (14-5.a).
Inspect work areas daily for adequate housekeeping and record the findings in daily inspection reports (14-5.c).
L
Load pickup: engage, tilt, and carry palletized and bundled materials
Overload or off-center load causes longitudinal or lateral tip-over
Verify load weight against the posted rated capacity before every pick and never exceed the rating, including reduced ratings at extended boom reach on telehandlers (18-8.i(2)).
Center the load on the forks, tilt the mast back, and carry the load only as high as necessary to clear the road surface (18-8.i(8)).
Use the manufacturer-approved attachment and load chart for non-palletized picks; keep the operator's manual on the machine.
M
Falling material strikes the operator or nearby workers
Use the overhead guard as protection against falling small material — and do not rely on it to withstand a falling capacity load (18-8.i(5)).
Band, block, or interlock loose bundles so the load is stable and secured against sliding or collapse before lifting (14-8.b(1)).
Do not move materials over or suspend them above personnel unless positive precautions protect them from falling objects (14-8.a(4)).
L
Traveling with loads across the site, including grades and congested areas
Struck-by: pedestrians or other trades hit by moving forklift or its load
Sound the horn at intersections, doorways, and blind corners; travel in reverse when the load blocks forward visibility, or use a spotter.
Operate at a speed that permits stopping safely for site conditions (18-8.i(7)) and keep to the established equipment routes.
Ensure all persons are in a safe position while materials are being loaded, unloaded, or moved (14-8.a(7), 14-8.b(8)).
M
Tip-over on ramps and grades
On all grades, tilt the load back and raise it only far enough to clear the road surface (18-8.i(8)).
When ascending or descending grades over 10 percent, drive loaded machines with the load upgrade (18-8.i(9)).
Keep the seat belt fastened and stay with the machine in a tip-over — do not jump.
M
Unattended machine rolls or is operated by unauthorized personnel
When leaving a PIT unattended, fully lower the forks, neutralize the controls, shut off power, and set the brakes; chock the wheels on any incline (18-8.i(4)).
Only trained, qualified, and designated operators per para 18-3 may operate the equipment (18-8.i(3)).
L
Stacking and storage in laydown areas and inside structures
Stacked material collapses onto workers
Stack, block, interlock, and limit the height of bagged, containered, bundled, or tiered material so it is stable and secured against sliding or collapse; stack as low as practical and never higher than 20 ft (14-8.b(1), 14-8.b(1)(a)).
Step back and cross-key bagged material at least every 10 bags high; do not stack cement or lime bags more than 10 high without setback (14-8.b(16)).
Stack manually handled lumber no more than 16 ft high on stable, level sills, and taper loose brick stacks above 4 ft (14-8.b(15), 14-8.b(17)).
Segregate noncompatible materials and store per the manufacturer's recommended method (14-8.b(11), 14-8.b(5)).
L
Material stored at openings or on platforms creates fall/falling-object hazards
Inside buildings under construction, keep stored materials at least 6 ft from hoist-ways and floor openings and 10 ft from exterior walls that do not extend above the stored material (14-8.b(6)).
Do not store material on scaffolds, work platforms, or runways in excess of load limits (14-8.b(9)).
L
Manual handling strains and sprains when breaking down loads
Follow the handling hierarchy: engineer out the handling need, then mechanical devices, then manual means with a handling aid such as a dolly or cart, then safe lifting techniques (14-8.a(3)).
Train employees on safe lifting techniques before manual handling tasks (14-3.a).
L
Hoisting suspended loads with a telehandler (winch, hook, or rigging configuration)
Suspended load drops, swings, or overloads the machine
Do not use PITs or telehandlers to hoist loads unless the equipment manufacturer allows it and provides the procedures (16-8.ee(1)); when configured to hoist and lower a suspended load, comply with Chapters 15 and 16 in addition to 18-8.i (18-8.i(1)).
Operators, riggers, and others involved in the hoisting operation must have written proof of qualifications (16-3.j, 16-8.ee(2)(b)).
Keep the manufacturer's load rating charts for the approved attachment on site and follow them (16-8.ee(2)(d)).
Rig with inspected slings and hardware per Chapter 15; never use banding or strapping as rigging to hoist bundled materials (14-8.a(6)).
Use taglines to control the load where its movement may endanger personnel; use only nonconductive taglines near energized lines (14-8.a(5)).
M
Elevating personnel on a forklift-mounted work platform (only where no other practical method exists)
Platform detaches, tips, or occupant is ejected during elevation
Use a forklift-mounted platform only when there is no other practical method, with a platform the forklift manufacturer specifically allows, referencing ANSI B56.6, with a compatibility letter on site if the platform is third-party (22-8.s(1)-(3)).
Securely attach the platform to the carriage and forks, secure the carriage and forks against pivoting forward, and deactivate any rotator (22-8.s(4)-(6)).
All occupants use fall restraint per Chapter 21 and maintain firm footing; do not tilt the platform (22-8.s(12)-(13)).
Set travel controls to neutral and the parking brake before elevating, verify the mast is vertical and the machine level and on firm footing, and verify the platform path is clear of electrical wires and overhead obstructions (22-8.s(11), (17)-(19)).
Operator remains at the controls the entire time personnel are elevated; never travel with the platform raised or occupied (22-8.s(15)-(16), (21)).
M
Refueling, parking, housekeeping, and demobilization
Fire during refueling or from fuel storage in the laydown area
Shut down the engine before refueling and refuel in a designated area away from ignition sources; a QP supervises storage, handling, and use of flammable liquids per 29 CFR 1926.152, NFPA 30/30A (14-4.d(2), 14-8.b(21)(a)).
Inspect dispensing hoses per the manufacturer's instructions and immediately replace hoses with cuts to reinforcement, blistering, soft spots, coupling slippage, or kinking (14-5.d(1)).
Keep the machine-mounted fire extinguisher charged and inspected (18-5.a(4)(j)).
L
Debris, dunnage, and banding left in work areas cause trips, punctures, and lacerations
Inspect work areas daily for adequate housekeeping and record findings in daily inspection reports (14-5.c).
Dispose of waste and scrap per 14-8.c and 29 CFR 1926.252; remove all nails from reusable lumber and dunnage before stacking it for storage (14-8.b(15)(c)).
Secure the machine at end of shift: forks fully lowered, controls neutralized, power off, brakes set, wheels chocked on inclines (18-8.i(4)).
L
Equipment To Be Used
Forklift (vertical mast, Class IV/V) with posted rated capacity plate (18-8.i(2))
Rough-terrain telehandler with load charts for each approved attachment (16-8.ee(2)(d))
Manufacturer-approved fork attachments, booms, and work platform (ANSI B56.6, 22-8.s)
PIT operator training per 29 CFR 1910.178 — classroom plus practical, on the same type of truck used on the job; employer certification with operator name, training date, evaluation date, and trainer identity (18-3.f, 18-3.f(1))
Refresher training and evaluation at least every 3 years, and after unsafe operation, an accident or near miss, a failed evaluation, assignment to a different PIT type, or a workplace change affecting safe operation (18-3.f(2))
Written proof of qualification for operators and riggers involved in suspended-load or personnel-hoisting configurations (16-3.j, 16-8.ee(2)(b))
Safe lifting techniques training for all employees performing manual handling (14-3.a)
AHA review and signature by every involved employee before starting work (2-6.d(2))
Fall restraint system use for any personnel working from a forklift-mounted platform (22-8.s(12), Ch 21)
Inspection Requirements
One-time qualified-mechanic inspection of each machine before initial use, report kept on site (18-5.a(2))
CP inspection with documented checklist before equipment is placed into use; checklist submitted to KO/COR; re-inspection at least annually and whenever equipment returns to the project (18-5.b(1))
Advance inspection of roads and shoulders for clearance and load capacity before machine passage (18-5.c)
Competent / Qualified Person Requirements
Equipment inspection Competent Person — inspects and documents each machine before it is placed into use, daily while in use, and at least annually (18-5.b(1)-(2)); designate by name on the AHA per 2-6.d(4)
Qualified Person — runs the scheduled maintenance program per manufacturer's instructions (18-5.a(1)) and supervises flammable liquids storage and dispensing (14-4.d(2))
Qualified riggers and operators with written proof of qualification for any suspended-load (rigging/winch/hook) configuration (16-3.j, 16-8.ee(2)(b))
Applicable EM 385-1-1 (2024) Sections
Ch 14 — Material Handling, Storage, Disposal, and Conveyors
14-8.a — Material Handling — handling hierarchy, taglines, no loads over personnel
14-8.b — Material Storage — stacking, stability, and clearance requirements
14-5 — Inspection Requirements — storage systems and daily housekeeping
29 CFR 1926.602(c) — Lifting and hauling equipment (Subpart O — Motor Vehicles, Mechanized Equipment)
29 CFR 1926.250 — General requirements for storage of materials (Subpart H)
29 CFR 1926.251 — Rigging equipment for material handling (Subpart H)
29 CFR 1926.252 — Disposal of waste materials (Subpart H)
29 CFR 1910.178 — Powered industrial trucks — operator training (invoked by EM 385-1-1 para 18-3.f)
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What EM 385-1-1 chapter covers forklifts and material handling?
Two places in the 2024 edition. Chapter 14 covers material handling, storage, disposal, and conveyors — the handling hierarchy, stacking limits, and storage inspections. Paragraph 18-8.i covers the machines themselves: all PITs, forklifts, and telehandlers must meet ANSI/ITSDF B56.1 for design, inspection, testing, maintenance, and operation, with operators trained per 18-3.f.
Do I need a separate AHA for telehandler suspended-load picks?
Not necessarily separate, but the AHA must cover it explicitly. Per 18-8.i(1), when a PIT or telehandler is configured to hoist and lower a suspended load by winch, hook, or rigging, Chapters 15 (rigging) and 16 (load handling equipment) also apply — including written proof of operator and rigger qualifications per 16-3.j. If your baseline forklift AHA does not address rigging, load charts, and those qualifications, add the step or write a dedicated AHA.
Can we lift workers on a forklift-mounted platform?
Only as a last resort. Para 22-8.s allows a forklift-mounted work platform only when there is no other practical method, and only if the forklift manufacturer specifically allows personnel lifting, the platform meets ANSI B56.6, occupants use fall restraint per Chapter 21, the operator stays at the controls, and the machine never travels while the platform is raised or occupied. An aerial lift or scaffold is almost always the correct choice instead.
What should the overall RAC be for forklift and material handling operations?
The overall RAC must not be lower than the highest job step RAC on the AHA (para 2-6.d(4)(f)). With the controls in this example applied, most steps land at Low, but struck-by pedestrian exposure, tip-over on grades, and suspended-load work typically remain Medium — so Medium (M) is the defensible overall RAC for a typical project. Remember the 2024 severity scale uses 'Moderate', not the 2014 term 'Marginal'.
Does the 2014 or 2024 edition apply to my contract?
Solicitations issued on or after 15 March 2024 fall under EM 385-1-1, 15 March 2024. Contracts awarded under the 2014 edition remain on it until completion. The editions number things differently — this activity cites Ch 14 and 18-8.i in 2024 style, while a 2014-edition AHA would use the old section-letter format — so match your citations to the edition your contract invokes.
What operator documentation will the GDA ask for at the preparatory meeting?
Expect to produce the employer's 1910.178 training certification for each operator (name, training date, evaluation date, trainer identity per 18-3.f(1)), the qualified mechanic's pre-use inspection report and the CP's documented placed-in-service checklist (18-5.a(2), 18-5.b(1)), and the signed AHA with every involved employee's signature per 2-6.d(2). For suspended-load configurations, add written proof of operator and rigger qualifications.