What Ontario's OHSA Regulation 851 Means for Your Forklift Fleet
Ontario's Industrial Establishments regulation (O. Reg. 851 under the OHSA) requires that powered industrial vehicles — forklifts, reach trucks, order pickers, pallet jacks — be inspected by a competent person before use, and that a more thorough annual inspection be completed by a qualified mechanic or technician. If you're running a service shop that handles this work, here's what you need to understand.
What Gets Inspected
A proper annual inspection covers the whole machine. Not just the obvious stuff. The major areas:
Load handling system — Forks for cracks, wear, and bend. Carriage for cracks and damage. Mast channels, rollers, and lift chains. Chain elongation gets measured, not eyeballed. Tilt cylinders checked for leaks and full range of motion.
Steering and brakes — Steering play, operation, and fluid levels. Service brakes and parking brake engagement. On electric units, regenerative braking function. These aren't check-the-box items — a forklift with soft brakes in a busy warehouse is a serious problem.
Propane system — On LP machines, this means the entire fuel system: cylinder, coupling, hose, regulator, and vaporizer. You're looking for leaks, wear, proper mounting, and valve condition. Propane items have no tolerance for "check it next visit."
Safety devices — Horn, lights (if equipped), backup alarm, seat belt or operator restraint, overhead guard integrity. All of it. Missing or non-functional safety devices are immediate write-ups.
General condition — Tires for wear and damage. Battery condition on electric units. Hydraulic fluid levels. Frame for cracks or damage. Counterweight fasteners. No deferred maintenance that affects safe operation gets signed off.
Critical Items Are Critical
Some findings are auto-fail. Cracked forks, inoperative service brakes, a leaking propane regulator, a compromised overhead guard — these machines don't go back into service until the repair is done and documented. There's no "flag it and run it light." If you're signing off on an inspection, you're signing off that it's safe to operate.
Shops that let customers pressure them into green-lighting a machine with a critical finding are one incident away from a much larger problem.
The Paper Trail
The inspection record needs the inspector's name and their competency documentation on file. Certificate number, expiry, and the scope of what qualifies them to sign. The machine-specific record needs: unit identification, inspection date, findings, any work performed, and the certifying signature.
This documentation isn't just for MOL audits. It's what your customer needs to show their insurance company, their own safety auditors, and anyone else who asks whether the fleet is compliant. Build the habit of producing clean, complete records — it's part of what you're being paid for.
Staying Ahead of Expiries
Annual certifications are exactly that — 12 months. Most shops have customers running 10, 20, 40 units. If you're not tracking expiry dates, you're depending on the customer to notice, and most won't until something happens.
A 30-day warning window gives you time to book the work before the cert lapses, not scramble after. When certifications lapse and a unit is still in service, the liability is on everyone in the chain.
What This Means for Your Shop
Four things to get right:
- Document inspector credentials and keep them on file, not in someone's head.
- Record findings clearly — "inspected and passed" is not a finding. Write what you checked and what condition it was in.
- Track unit-level expiry dates so you can proactively follow up with customers before certs lapse.
- Don't sign off on critical findings. Tag the machine out, document the reason, and make the repair before it goes back into service.
The regulation exists because people get seriously hurt when powered industrial vehicles aren't maintained. That's not abstract — it happens at real facilities with real machines. Getting this process right is the job.