Forklift and Powered Industrial Truck Safety

No. Refresher training only needs to be conducted when operators are found to be operating unsafely, have been in an accident or near miss, receive a poor evaluation, or when there are changes in the workplace or type of truck. OSHA does, however, require an evaluation of each powered industrial truck operator’s performance at least once every three years.

There is no requirement to keep records under 1910.30. OSHA states in publication, “Training Requirements in OSHA Standards,” however, that it is a good idea to keep a record of all safety and health training. This serves several important purposes, including demonstrating compliance with applicable standards. OSHA says that documentation can also supply an answer to one of the first questions an incident investigator will ask: “Did the employee receive adequate training to do the job?”

In terms of who can conduct operator training and evaluation, OSHA requires in 1910.178(l)(2)(iii) that the trainers have the “knowledge, training, and experience” to train operators and evaluate their competence. The OSHA standard does not further define this requirement or set any specific certifications. However, OSHA discusses trainer qualifications in the preamble to the December 1998 final rule: “OSHA has concluded that the final rule should adopt a performance-oriented approach to the qualifications of trainers and evaluators. As discussed above under issue 1, OSHA does not have the resources to evaluate and certify trainers and does not consider it necessary to do so. Trainers and evaluators with different backgrounds can achieve the level of ability necessary to teach and evaluate trainees. To meet these commenters’ concerns, OSHA has eliminated the term “designated person” from the final rule and has instead described the knowledge, skills, or experience any trainer or evaluator must have under the standard.”

OSHA does, however, clarify in a Letter of Interpretation the “experience” aspect of the trainer requirements: “A trainer must have the “knowledge, training, and experience” to train others how to safely operate the powered industrial truck in the employer’s workplace. In general, the trainer will only have sufficient “experience” if he has the practical skills and judgment to be able to himself operate the equipment safely under the conditions prevailing in the employer’s workplace. For example, if the employer uses certain truck attachments and the trainer has never operated a truck with those attachments, the trainer would not have the experience necessary to train and evaluate others adequately on the safe use of those attachments. However, the standard does not require that the trainers operate a PIT regularly (i.e., outside of their operator training duties) as part of their job function or responsibility.”

Federal OSHA has no requirement that a forklift operator have a valid driver’s license. OSHA does require that every forklift operator be trained and certified to operate the powered industrial truck in the workplace, and that the operator’s performance be evaluated on the provisions of 1910.178(l)(3) every three years. The employer must have a record documenting that the driver has successfully completed the training. That is the only operating “license” required by OSHA.