Forklift Operating Rules Every California Employer Must Post (GISO 3650 & 3664)
Most California facilities we walk into have most of a forklift program in place. The piece that is missing more often than any other is the posted set of operating rules.
Most California facilities we walk into have most of a forklift program in place. Operators are trained. Certificates are filed. The daily inspection log is at least partially used. The piece that is missing more often than any other is the posted set of operating rules. Cal/OSHA does not treat posting as optional. Under General Industry Safety Order §3664, every employer using powered industrial trucks has to post a set of operating rules drawn from §3650(t) and enforce them. The fix is small. The exposure if it is missing is not.
This piece covers what §3650(t) and §3664 actually require, what an inspector reads when they look at the posting, where the rules go, and the patterns that turn a posting into a finding. For the full overview of how training, evaluation, and posted rules fit together, see our Cal/OSHA forklift operator training and evaluation guide.
What §3650(t) and §3664 Actually Say
Two Cal/OSHA Title 8 sections work together.
- §3650(t) sits inside the General Industry Safety Orders for industrial trucks. Subsection (t) is the list of operating rules that govern how powered industrial trucks are run inside a California facility. The list covers everything from who is allowed to operate the truck, to speed, to load handling, to fueling, to pre-shift inspection, to parking. It is the operating manual the regulation expects every facility to follow.
- §3664 is the posting and enforcement section. It requires every employer using industrial trucks to post a set of operating rules based on §3650(t) and to enforce those rules among operators. Posting alone is not enough. Enforcement is part of the standard. The federal equivalent is 29 CFR 1910.178. Inside California, §3650(t) and §3664 are the citations that control.
The practical takeaway: the operating rules in §3650(t) are not just an internal Cal/OSHA list. They are content the employer is supposed to lift out and post, in a form operators can read on the floor, in the languages the operators read.
What the Posted Rules Cover
The §3650(t) rule set is long enough that few facilities post all of it verbatim. The version most California facilities use is grouped by what the operator is actually doing on a shift. The categories below are how the CDMS posted Operating Rules for Industrial Trucks sheet is organized for clients. Each one ties back to one or more provisions of §3650(t).
| Category | What the rules cover |
|---|---|
| Operator authorization | Only trained, evaluated, and authorized employees operate the truck; no one under 18 operates a powered industrial truck in a hazardous occupation |
| Mounting and starting | Seat belt fastened before moving; controls checked; nothing on the operator’s lap, in their hands, or blocking their view |
| Travel and speed | Speed limited to conditions; horn sounded at intersections, blind corners, and doorways; looking in the direction of travel; no passengers |
| Load handling | Loads centered, tilted back, carried low; no loads above rated capacity; data plate consulted when in doubt; loads do not obstruct vision |
| Pedestrian safety | Pedestrians yielded the right of way; safe distance maintained; no one allowed to walk or stand under elevated forks or a raised load |
| Ramps, grades, and dock plates | Load uphill on grades; no turning on grades; dock plates inspected and rated for the load before crossing |
| Parking and shutdown | Forks lowered to the floor, controls neutralized, brake set, key removed, truck not left running unattended |
| Refueling and battery charging | Engine off and area ventilated for propane or gas; eye protection and PPE in battery rooms; vents checked before charging |
| Pre-shift inspection | Each truck inspected before being placed in service; defects pull the truck out of service (this is §3650(t)(7), and it is also the basis for the daily forklift inspection checklist Cal/OSHA expects) |
| Maintenance and out-of-service | A truck with a safety defect is tagged, removed from service, and not returned until the defect is corrected by an authorized person |
The list is shorter on the wall than this table suggests. A standard CDMS posting is one or two pages of plain numbered rules. The point is that an operator can read the sheet without legal training and a Cal/OSHA inspector can match every line back to §3650(t).
Where the Rules Get Posted
§3664 says the rules are posted. It does not specify a single wall. In practice, the placement that holds up to inspection puts the sheet in front of operators at the points they will actually look at it:
- Inside the forklift charging or fueling area
- At the dispatch board or supervisor station where operators sign in for a shift
- On or near the toolbox station where pre-shift inspection logs are kept
- Inside the warehouse or shipping office where operators are briefed
A single posting in the breakroom is not enough if operators never set foot in the breakroom during a shift. We have walked facilities where the operating rules were laminated and beautifully framed in the front office and not visible anywhere on the warehouse floor. That is a posting on paper, not in practice.
Language. For a workforce that reads Spanish, bilingual posting is the defensible practice. It supports §3664 enforcement and the §3203 requirement that safety communication be readily understandable to affected employees. The English-only posting in a bilingual workforce is one of the more common deficiencies we find.
What an Inspector Reads
A Cal/OSHA inspector who is reviewing a forklift program will usually do three things in connection with the operating rules:
Find the posting.
They walk to the area where operators work, not to the office, and ask where the operating rules are. If they cannot find the sheet within a few minutes, the program has a posting gap regardless of what is on file elsewhere.
Match it back to §3650(t).
The sheet does not have to quote the regulation verbatim, but it does have to cover the substance. A sheet missing pre-shift inspection, parking, load handling, or pedestrian safety reads as incomplete.
Test enforcement.
Posting is half of §3664. The other half is enforcement. Inspectors will ask supervisors how they handle an operator who runs without a seat belt or carries a load with their forks raised. If the answer is “we tell them not to,” and there is no documentation behind it, the enforcement side of the standard is weak.
The inspector is not trying to catch a facility off-guard. They are checking whether the program is real or whether the paperwork was assembled the morning of the inspection. A current posting, in the right places, in the right languages, plus a documented practice of correcting unsafe operation, answers the question.
Common Deficiencies We See on the Posting Side
A few patterns show up repeatedly when we walk a California facility for the first time:
- No posting at all. The training and records exist; the §3664 sheet was never created. Most common in facilities that built their program from an online certificate vendor’s template.
- A posting that has not been updated in years. Operators have changed, truck types have changed, the layout has changed, and the sheet still references equipment that left the facility.
- English-only postings in a Spanish-speaking workforce. Common in food processing, warehousing, and distribution.
- The sheet posted in the office, not on the floor. Visible to managers, invisible to operators.
- Posting without enforcement. The rules are on the wall and operators are observed routinely violating them without correction. Inspectors notice this faster than missing paperwork.
These are not exotic findings. They are the patterns we close out during a gap assessment, before they show up in an enforcement file.
How the Posted Rules Fit in the Full Program
The §3664 posting is one component of a complete Cal/OSHA forklift program. The others are operator training and evaluation under §3668, the daily pre-shift inspection under §3650(t)(7), and the training records that prove operators are current. All four work together. For how the posted rules fit alongside the other components, see how to build a forklift safety program for a California facility and the daily forklift inspection checklist Cal/OSHA expects.
For California facilities that want the posted rules, the inspection log, the training records, and the operator evaluations handled together so nothing drifts between renewals, that work fits inside our ongoing compliance management service.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
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