On Safety: Training for powered industrial trucks

A common question we receive concerns the requirements for powered industrial truck training. Although the literature includes many references and discussion points, the following provides an overall summary of OSHA’s training requirements under 1910.178(l). This summary is based on references provided at the conclusion of this blog post.

OSHA requires that operators of PITs be trained before operating the equipment independently. That training must consist of instruction – classroom (lecture based) and practical training – on the safe and proper operation of the PIT, the hazards of operating the vehicle in the workplace, and the requirements of the OSHA standard on PITs. Operators who have completed the training must then be evaluated while they operate the PIT in the workplace. Additionally, operators must periodically be evaluated (at least once every three years) to ensure their skills remain at a high level and receive refresher training whenever there’s a demonstrated need (e.g., a crash, reckless driving, a near miss).

To maximize the effectiveness of the training, OSHA doesn’t require training that’s duplicative of other training the employee has received, provided the operator has been evaluated and found competent to operate the PIT safely. OSHA training provisions also require the employer to certify that training and evaluations have been conducted. The person who conducts the PIT training, refresher training, evaluations and certification of the operator, under 1910.178(l), need not be employed by the employer of the operator. Such third-party training, including appropriate on-the-job training, may be provided by an employers association, a labor union, a joint labor-management training organization or any other organization meeting the requirements of the standard (such as the National Safety Council). However, any OSHA citation related to PIT training discrepancies or deficiencies would be issued to the host employer.

OSHA does require that PIT training be based on:

• The general principles of the safe operation of the vehicle
• The type of PIT being used
• The hazards present when using a forklift in the workplace
• The general safety requirements of the OSHA standard on PIT

Before any employee can operate a PIT in their workplace, the employer must evaluate the forklift operator’s performance and determine if they can operate the PIT appropriately. The operator must be able to demonstrate that they can do the job safety and properly.

Under 1910.178(l), forklift training requirements include:

• Operating instructions, warnings and precautions for the type of PIT the employee will be using
• The differences between a PIT and an automobile
• PIT controls and instrumentation, including where they’re located, what they do and how they work
• Engine and motor operation
• Steering and maneuvering
• Visibility and attachment adaptations, operation, and use limitations
• PIT capacity
• PIT stability
• Vehicle inspections and maintenance that the employee will have to perform, including battery charging and/or fuel tank exchanges (refueling and battery charging)
• Operator limitation of the forklift
• Vehicle speed limitations and requirements
• Use of seat belts

Training on workplace-related topics also must include:

• Surface conditions, including where the vehicle is to be operated, slippery conditions, and surfaces with obstructions or uneven surfaces; floor load limits; and overhead clearances
• Composition of the loads expected to be carried, including weight, size and positions
• Load capacity and maximum loads
• Load stability and balance
• Load handling, manipulation, stacking, safe handling load preparation, how to approach the load, mast position, fork position, lifting the load, lowering the head, high tiering, trucks and trailers, and railroad cars
• Pedestrian traffic and right of way
• Narrow aisles and other restricted places where the vehicle will be operated, including any necessary training on reach trucks, order pickers and safe stacking rules
• Hazardous locations, including training on designated locations, indoor air quality and carbon monoxide
• PIT operation on ramps and other sloped surfaces
• Operation in closed environments and other areas where ventilation may be insufficient
• Any other unique workplace environment or environmental condition

For operator certification, the employer must include the following information on the certification:

• Operator name
• Training date
• Evaluation date
• Name of the individual performing the training and evaluation

Once the operator has been certified, the certification is good for three years. At the end of the three-year period, the operator must receive refresher training. That refresher training needs to include an evaluation of the effectiveness of the training and must ensure the operator has the knowledge and skills necessary to safely operator the PIT.

If the operator demonstrates issues or deficiencies in the safe operation of the PIT, then refresher training is required. For example:

• The operator was observed operating the PIT in an unsafe manner.
• The employee was involved in a near miss or incident.
• The evaluation of the operator notes deficiencies.

Refresher training also is required when:

• The driver or operator is assigned to a different PIT.
• A condition in the workplace changes in such a manner that it could affect the safe operation of the PIT.

References

1. 29 CFR 1910.178(l) – Powered Industrial Trucks
2. TWI Bulletin No. 7
3. OSHA Training Requirements – Powered Industrial Trucks (forklift operator training)
4. NSC Powered Industrial Truck Training
5. 7 Tips for Powered Industrial Truck Training
6. Western Carolina University Powered Industrial Truck (Forklift) Safety Program – 1910.178 OSHA Powered Industrial Trucks