Training, Evaluation and Certification Requirements for Forklift Operators
Training your employees in the proper performance of their job is time and money well spent.
I have observed that companies with a strong safety culture consider training as an investment rather than an expense. For these companies, an effective program of safety and health training for their employees usually results in fewer injuries and illnesses, better morale, and lower insurance premiums, among other benefits.
Many OSHA standards explicitly require the employer to train employees in the health and safety aspects of their jobs. Other OSHA standards make it the employer's responsibility to limit certain job assignments to employees who are "certified," "competent," or "qualified," meaning that they have had special previous training, in or out of the workplace. These requirements reflect OSHA's belief that employee training is a necessary and essential element of every employer's safety and health responsibility for protecting workers from injuries and illnesses.
One such standard, 29 CFR 1910.178, Powered Industrial Trucks, requires employers to “ensure that each powered industrial truck operator is competent to operate a powered industrial truck (forklift) safely as demonstrated by the successful completion of training and evaluation” as outlined in the standard.
These training requirements for powered industrial trucks also apply to OSHA standards 29 CFR 1915.120 (Shipyard Employment), 29 CFR 1917.1 (Marine Terminals), 29 CFR 1918.1 (Longshoring) and 29 CFR 1926.602 (Construction). OSHA put these requirements into effect since approximately 100 fatalities occur each year from powered industrial trucks. The 1910.178 Powered Industrial Truck standard ranks seventh on OSHA’s “Top 10 Most Frequently Cited Standards” list.
OSHA requires the following as part of the standard:
1. Operator training - Safe operation. The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial safely, as demonstrated by the successful completion training and evaluation specified in this paragraph.
Prior to permitting an employee to operate a powered industrial truck (except for training purposes), the employer shall ensure that each operator has successfully completed the training required by 29 CFR 1910.178 paragraph (l), except as permitted in paragraph (l)(5).
2. Training program implementation.
(A) Trainees may operate a powered industrial truck only:
- Under the direct supervision of persons who have the knowledge, training, and experience to train operators and evaluate their competence; and
- Where such operation does not endanger the trainee or other employees.
(B) Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, videotape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.
(C) All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.
Note: In a letter of interpretation dated July 23, 2003, Mr. Richard E. Fairfax, of the Directorate of Enforcement Programs, wrote that “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. A person(s) who conducts operator training and evaluation does not need to be “certified” as a forklift trainer, but they do need to have the knowledge, training, and experience that would be obtained from their own previous formal training, knowledge of forklift operations, and experience as an operator.
3. Training program content. Powered industrial truck operators shall receive initial training in the following topics, except in topics that the employer can demonstrate are not applicable to safe operation of the truck in the employer's workplace.
A. Powered Industrial Truck (Forklift) topics:
- Operating instructions, warnings and precautions for the types of truck the operator will be authorized to operate;
- Differences between the truck and the automobile;
- Truck controls and instrumentation: where they are located, what they do, and how they work;
- Engine or motor operation;
- Steering and maneuvering;
- Visibility (including restrictions due to loading);
- Fork and attachment adaptation, operation, and use limitations;
- Vehicle capacity;
- Vehicle stability;
- Any vehicle inspection and maintenance that the operator will be required to perform;
- Refueling and/or charging and recharging of batteries;
- Operating limitations;
- Any other operating instructions, warnings, or precautions listed in the operator's manual for the types of vehicle that the employee is being trained to operate.
B. Workplace related topics:
- Surface conditions where the vehicle will be operated;
- Composition of loads to be carried and load stability;
- Load manipulation, stacking, and unstacking;
- Pedestrian traffic in areas where the vehicle will be operated;
- Narrow aisles and other restricted places where the vehicle will be operated;
- Hazardous (classified) locations where the vehicle will be operated;
- Ramps and other sloped surfaces that could affect the vehicle's stability;
- Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust;
- Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation.
C. The powered industrial truck safe operating requirements outlined in 29 CFR 1910.178.
Note: The employer should provide each forklift operator with a copy of 29 CFR 1910.178 and verify that each operator is well versed in the standard’s mandated safety requirements.
4. Refresher training and evaluation.
A. Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by 29 CFR 1910.178 paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely.
B. Refresher training in relevant topics shall be provided to the operator when:
- The operator has been observed to operate the vehicle in an unsafe manner;
- The operator has been involved in an accident or near miss incident;
- The operator has received an evaluation that reveals that the operator is not operating the truck safely;
- The operator is assigned to drive a different type of truck; or
- A condition in the workplace changes in a manner that could affect safe operation of the truck.
C. An evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years.
Note: In a letter of interpretation dated August 1, 2005, OSHA’s Fairfax wrote that: “In most cases, the person conducting the evaluation would do two things: first, observe the powered industrial truck operator during normal operations to determine if the operator is performing safely, and second, ask pertinent questions to ensure that the operator has the knowledge or experience needed to operate a truck safely. In some cases, because of the danger or complexity of the operation, the extent of the change in conditions, or the operator's need for additional skills, the evaluation will need to be lengthier and more detailed. The triennial evaluation ensures that the operator has retained the necessary knowledge and skills for safe operation of the vehicle.”
5. Avoidance of duplicative training. If an operator has previously received training in a topic specified in 29 CFR 1910.178 paragraph (l)(3), and such training is appropriate to the truck and working conditions encountered, additional training in that topic is not required if the operator has been evaluated and found competent to operate the truck safely. This means that an employer may accept an employee’s earlier training, so long as it is applicable to the new workplace, but the employer must still conduct an evaluation of the operator.
6. Certification. The employer shall certify that each operator has been trained and evaluated as required by 29 CFR 1910.178 paragraph (l). Certification shall include the name of the operator, the date(s) of the operator’s training, the date(s) of the operator’s evaluation, and the identity (name) of the person(s) performing the training or evaluation. Employers sometimes believe that certifications are completed by outside, third party trainers. The certification should be completed by the employer, and retained until a new certification is completed.
It is always a good idea for the employer to keep a record of all safety and health training. Records can provide evidence of the employer's good faith and compliance with OSHA standards. Documentation can also supply an answer to one of the first questions an accident investigator will ask: "Was the injured employee trained to do the job?" Ideally, safety and health training should be provided before problems or accidents occur.
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