OSHA’s Frequently Asked Questions about Powered Industrial Truck Operator Training
Dennis’ Comment: (i.e., skid steer (bobcats), front end loaders with forklift attachment-not part of the forklift regulation)
The underlined above means NO ON THE JOB TRAINING for new hires unless the trainer is a designated and qualified trainer and you will have to defend the qualification of the trainer (s) if the training of employee is brought into question. This also means you cannot conduct “peer to peer” training of a forklift operator……..only a designated and competent trainer can certify your operators.
For example, “Big Bob” may be the best forklift operator and the one with the most years with your company but unless you formally designate him as your trainer, he cannot be training your other forklift operators. Also, the best operators are not always the best trainers so don’t automatically assume that experience and knowledge of forklifts translates automatically to competence in training employees. This is a classic mistake and assumption that often leads to a total mess and lack of coordinated and uniform training of a workforce. Think about it……….asking or “volunteering” a paid employee to train peers and often without increased compensation or coverage of that employee’s work while they are performing the training will most often result in no training taking place, frustration and resentment of the “voluntold” trainer. The program will lapse or become an hour long joke of a session where a basic safety video is played and a 10 question True and False test is given and considered good enough.
In addition, it states in the underline above that “PRIOR to operating the truck in the workplace”, employees must be certified by the employer to be “competent to operate a powered industrial truck safely”.
So, “PRIOR to operating the truck in the workplace” does not mean “while operating in the workplace”. PRIOR TO and WHILE OPERATING do not mean the same thing the last time I checked. In other words, no employee should be on the forklift UNTIL they have successfully completed the formal and practical training required by the regulation COMPLETELY………..no gray area on this and no excuse of “we don’t have the time to train them” is acceptable. Delivering classroom training and then delaying the driving evaluation due to production needs while allowing the same employee (s) to operate the forklifts until you have the time to complete the training is NOT acceptable.
In addition, the employer MUST include site specific hazards and situations of the workplace environment in the training session that is also not directly mentioned or covered in the list of topics from OSHA. OSHA cannot possibly provide a list of site specific and situational hazards for every single worksite and facility in the country so employers have to identify and then include training solutions for those hazards and situations for the trainee.
Keep in mind on this point that you will be questioned as to the standard you use to pick internal trainers for forklift safety. That is, you need to develop a company standard for trainers (e.g. how much experience, knowledge, education do the trainers really need to train operators specifically at your facility on your forklifts) and ensure that the standard is consistently met across all those individuals designated as “trainer”. You will be challenged if it is uncovered that you have some trainers with very limited background or proven skills and understanding of safe operation of these vehicles while other trainers have years or decades of direct experience and knowledge. This is quite a common situation for many organizations and it exposes those organizations greatly to citations for “inadequate training”, obviously.
Various Internet sites are devoted to forklift safety. Private companies who provide forklift safety training services, including videos and written programs, can be located on various Internet websites. Most videos can be either leased or purchased. One important thing to remember is that simply by showing employees a video or videos on some aspect of forklift safety does not meet the full requirements of the OSHA standard. Site specific information must be conveyed as well as a method to evaluate the employee’s acquired knowledge subsequent to the training.
You have to be discriminating when/if you are choosing training materials from the internet. Most of the material to be purchased there falls way short of the mark when it comes to adequately covering the regulations and gaining the employees’ understanding of the various rules and regulations. These videos skip the entire “site specific” requirement of the training standard.
Also, video and computer based learning is “one way” learning and does not afford the viewer the opportunity to ask questions at the point where the ambiguous term or unrecognized industry jargon is used in describing these rules and regulations. Thus, the viewer misses the entire point which defeats the training purpose. Watch one of these videos and see how ambiguous and sometimes confusing the delivery of the material can be and then consider your employee/operator and how they may interpret the wording or statement.
5. If my employees receive training from an outside consultant, how will I know that these employees have been adequately trained?
The question above is suspect in terms of common sense. How will you know if employees are trained adequately? That should not be a question of someone in charge of choosing the method or source to train employees. To even think about using and outside source for your training, the person or persons selecting this source must be expert trainers themselves first or, at the minimum, acquire the consultation of an expert trainer that can evaluate the training source. If you hire a training company or trainer without knowing what you need or will receive from that outside source, it is your fault completely for not vetting them and ensuring it is adequate and completely in compliance. What are you going to do? Go with a training company or training content system without knowing if it even meets both the OSHA basic standards and your site specific standards? Crazy if you do and hope luck is on your side.
Also, to use a little sarcasm here, don’t choose a safety training resource that offers safety training as a “side business” or product extension of their core business. A national uniform company offers safety training that, from my contacts reports, is basically a joke in terms of training quality. You wouldn’t have your doctor fix your car for you, would you? Or make your favorite pizza? So don’t do the same with safety training as there is too much at stake. Going cheap on safety training is going to get you cheap results and that is a fact.
This answer is typical government doublespeak to appease major politically driven protesters of the regulation and the renowned final rule for PIT Safety from 1998. How are you going to evaluate and document such without a written test? I guess you can take video of the trainee but that really isn’t practical in the real world. The administration and archiving will be huge for that. You can use the personal testimony of your designated trainer? But that won’t work if that in-house trainer ends up leaving the company at some point and an incident occurs involving an employee who was trained by that now defunct trainer. Again, you have to show proof of why you have certified an operator as “safe to operate” for OSHA and, in reality, compliance officers are going to have a very tough time believing this was done correctly and properly by means of a verbal evaluation. Good luck with that.
The consensus method is to require written testing of the operators knowledge of safe operation of the vehicle and this written test should be comprehensive to cover the entire spectrum of 1910.178 including power source safety and operator interaction (which most do not). It then should include specific written testing on site specific hazards and situations that are unique to the company and the site where the employees are operating forklifts. My guidance is to create or purchase a knowledge test with no less than 50 multiple choice/True/False questions or both. Anything less than this range of questions on a test for forklifts is incomplete.
Licenses (incorrect term for starters) from past employers are absolutely worthless to a new employer for forklift certification purposes. The wallet cards or wall certificates are symbolic and carry no official value in practice. Wallet cards may assist a company to help identify who may and may not be authorized by the company to operate a forklift at their facility. That is the single function of such symbols. In fact, some companies will use hard hat or bump cap stickers instead of cards but the purpose is still just internal identification only.
So #9 means you need to keep classroom tests, hands-on tests and the sign in sheets for each employee that operates a powered industrial truck. This should not be a big deal but, in practice, often becomes the Achilles heel of a training department because it is not maintained or enforced on the trainer or outside training company. When audit or investigation time comes, records are not found or have been lost or misplaced. In some cases, safety staff leave the organization for other employment with those records because they were not directed by their superiors to archive the records on a company network drive or some other record storage system. The safety staff may have been EXPECTED or ASSUMED to be doing this but to everyone’s amazement when asked for them, the records cannot be located because they were never archived. If the company thinks that not having those records on hand because a past safety staffer took them or misplaced them is an excuse, they will find themselves dead wrong.
Keep training records as long as you can and that should be a long time because of digital technology. The reason is the civil legal proceedings that may come up as a result of an employment situation years prior to the three year records retention rule state above. It is also a good idea to keep these records for posterity so that an organization that is rapidly changing, expanding or even moving can assess their training situation and history from a quality standpoint based on past records.
Accountability is key to prevent forklift accidents and I don’t just mean forklift operators. Accidents occur with this equipment for a number of reasons and many causes or influences are incurred in the same accident.
However, there is some very definitive and straightforward reasons why forklift accidents occur and the “stated reason” is often no more than a result of something deeper that is a problem. Poor facility layout, for example, can require unreasonable situational adjustments and skills from forklift operators. I have been in facilities that literally had less than on 60 watt light bulb for every 200 yards of warehouse space……..not kidding. I’ve been in facilities where overstock was so bad that striking adjacent fixtures and product was just an accepted part of forklift operation.
Likewise, even facilities that had been laid out to offer plenty of room and space for PIT operation would still incur regular accidents and incidents. These situations were totally because of operator negligence and carelessness. The company was at fault, however, for allowing these operators to have second and third chances after committing an incident or, in some cases, not even addressing the issue at all except to exhale in frustration!! The line management and safety staff were not allowed to discipline or attempt to discipline these employees for fear of some DOL charge or investigation. Funny that the ones trying to avoid the DOL didn’t realize that OSHA was part of the DOL and so either way they get the DOL. In other cases, it is just all around apathy by both operators and management when it comes to accidents or “near misses”. What is a near miss? Is there then a “far miss”? What distances constitute a “near miss” versus “no miss”? No one can explain that term to me completely. Such ambiguous judgement measures used practically will land you at the wrong end of legal case and cost you some serious dollars. “I saw Tommy riding around with his forks and load up in the air but since he didn’t tip over at that time and didn’t come CLOSE to hitting anything or anyone, it wasn’t a NEAR miss so I didn’t think his driving was wrong”………if a tree fell in the forest and there was no one around to hear it fall……………in other words.
Recommend you do a practical (hands on) evaluation about every three months. Retention of information is low without reinforcement of that information so if you really want your employees to know and operate safely, you have to reinforce the safety training standards much more frequently than three years. OSHA knows this but got beat up politically when they wrote their FINAL RULE for PITs so this requirement was a consolation to the anti-training special interests. If you want to read about that, look up https://www.osha.gov/laws-regs/federalregister/1998-12-01-1
1. The operator has been observed to operate the vehicle in an unsafe manner.
2. The operator has been involved in an accident or near-miss incident.
3. The operator has received an evaluation that reveals that the operator is not operating the truck safely.
4. The operator is assigned to drive a different type of truck.
5. A condition in the workplace changes in a manner that could affect safety operation of the truck.
All 5 above plus quarterly whichever is more frequent. Retention of the original training material content can be as much as 75% 90 days later and from then on until the next re-certification. Just as the saying goes, “whatever gets measured gets done”. If you focus on forklift safety by creating a training and accountability structure for your organization, I can guarantee improvement in both safety and productivity. If you put the structure in place correctly and diligently follow through on the follow up and periodic refresher training sessions and you still see no improvement, you should probably address the other factors…………..the people being hired or the work environment. At that point, at least you won’t have to wonder if the training program is causing your forklift incidents or problems……..it isn’t so other factors are doing so and your search for the cause to correct is narrowed.
14. If my employees have already received training, or have been operating trucks for many years, must I retrain them?
Once again, federal government communication doublespeak and weakness in response to special interest and political pressures. The answer to number 14 above reads as if to contradict the three year recertification requirement, doesn’t it? Think about this, too. How many work environments will stay exactly the same for decades or even one decade whereby you can claim that no further training on site specific hazards is required for current operators? Probably none. It sets you up for a belief that your employees only need to receive training once because the language is ambiguous and contradictory. No wonder anti-OSHA forces do get their way in some cases as a result of such ambiguity and lack of clarity.
Don’t mess around with this. Have a written classroom test and a practical driving observation test. Make the tests according to a 100% grading scale with 80% the minimum for certification. Classroom test of 50 questions would then demand focus and attention from trainees and excellent instruction by trainers. This is all achievable by any company or organization if they have the correct training content and the correct instructor/coaches heading up the training effort.
16. Does OSHA provide training to my truck operators?
This should be your first clue when some individual or some company is vying for your attention; when they claim to be OSHA certified or approved, you know they are a scam or a charlatan. OSHA doesn’t endorse any private company nor do they provide any training services. They have “authorized” trainers from the private sector conducting training of the OSHA 10 and 30 hour courses and on faculty at the OSHA Training Institutes but those bodies are hired by OSHA and not part of the DOL or Federal Government labor pool, directly. Thus, they don’t pick winners and losers in the private sector by mission and definition of purpose. They are supposed to support all organizations and enforce all regulations for all affected employers, equally.
This means “trained” BEFORE they actually start operating the vehicle in the workplace independent of a trainer present. There is no “learn as you go” mitigation in this situation for properly training and certifying the operator. If you authorize someone to operate a powered industrial truck, including powered pallet jacks (rider type or walker) and they have an accident, you may be cited for inadequate or lack of operator training because your attempt or gesture at a training program was incomplete. You have to get this correct if you truly want to keep everyone safe and all your products and facilities safe from these imposing and potentially dangerous vehicles.
If you have operators that you happen to notice are physically impaired in terms of their ability to operate these vehicles, you need to get them OFF the vehicle, immediately. If it turns out you are wrong about the symptoms or behavior for some reason, so be it. Nothing wrong about being overly cautious or concerned. What is wrong is doing nothing or making accommodations for an operator who cannot walk, cannot turn their head, cannot buckle the seatbelt, cannot stand on the operator’s platform or cannot judge the distances due to a lack of depth perception. You need to get this operator off the vehicle and have his physical situation and condition addressed by your HR people or your company legal department. Letting these operators continue or tell you that the condition is “no big deal” or a passing thing is tantamount to being negligent and willfully allowing a potentially dangerous hazard to exist in your workplace……….career-ending if you are the safety pro in charge.
As stated above, if you have multiple vehicle classes (there are 7 forklift classes per OSHA/ANSI) and you intend to have your operators certified and authorized on multiple classes, each class of vehicle has to be included in both the classroom training session and the hands-on evaluation and training part. There is no one size fits all training program or situation that will satisfy this requirement. You should account for this in terms of the training time necessary, as well. For example, if you want to certify your operators to operate a sit down, a narrow aisle stand up and an electric pallet jack, you will have to conduct a separate hands-on evaluation of that operator for all three classes of vehicles. Thus, if you have 20 operators, you have 60 evaluations to conduct (20 operators X 3 Evaluations each). A proper forklift driving evaluation should take between 15 and 20 minutes per operator so using the 20 minutes as a guide and conservatively speaking, in this situation you would need to allow 20 hours or 2.5 days (8 hour days) just to evaluate properly those 20 operators on the three classes of vehicles you have on hand. You should also add some time “padding” for those that fail the first round and need additional corrective instruction because you’ll need to do that corrective instruction and then again have them successfully take another hands-on evaluation for the record.
As far as new operators or those employees who have never been on a forklift, the training that they need will be extensive and comprehensive. They will need to know how the operating controls and functions of the vehicle, including attachments, actually work. They will have to be trained on how to move, maneuver and safety negotiate any facility hazards. They will need to know how to inspect the vehicle properly, how to safely interact with the forklift power source, propane or battery, diesel or other, and all the associated safety protocol for that particular power source. Even if you have a vendor or inside employee who takes care of the power source supply and maintenance, operators are required to know how to interact safely and correctly with those sources, as well. This also includes the specific type of PPE that an operator must be using when changing a propane cylinder or when connecting batteries to chargers. It also includes training on operator safety reaction when they have an emergency of some kind with the power source.
Dennis’ Comments: Answered above.
This is a big void when it comes to ensuring that forklift operators are actually safe on the vehicle and that this safe status is confirmed. Temporary agencies, first of all, are not staffed with industrial safety recruiters or even anything close to that knowledge. In most cases, the staffing agency recruiter is trained in customer service skills and over years of working in the industrial recruiting sector, they may learn some of the day to day job responsibilities or knowledge about such skills as operating a forklift. By and large, their staff turnover is about 50% on average so chances are you are dealing with an agency that may show lots of candidates with “forklift certified” on their resume but actually turn out to be no good to you because they have no experience with the class of vehicles that your company has on hand. A forklift operator that has spent years operating a sit down forklift can struggle and struggle to learn and understand a narrow aisle forklift as much as someone who never operated a forklift of any kind. Staffing agency recruiters almost never know this distinction so they will not even venture to screen correctly for the correctly experienced operator and they definitely will not have resources to help you train and oversee the proper and fully safe placement of an operator in your company. They will send candidates that have “forklift experience” and let you sort out the rest of the requirements to your utter frustration.
What can you do if you are using a staffing agency and you want ensure you meet the OSHA expectations while improving the quality of new hires and new hire retention rates?
Get a meeting with the staffing agency management and precisely layout what your need for their recruiters to find for you in terms of experience in class of vehicle from their recruiting pool. Next, set up initial training (classroom part) for those candidates back at the Staffing Agency offices so that classroom training is already done when the candidate shows up to meet your staff for the first time. When the candidate presents themselves to you as sent by the agency, you immediately take them to your forklifts and ask them to perform some very simple tasks with that forklift which, if they are truly experience, they should be able to perform fairly easily and without a lot of delay. If you are the trainer or you have an inside trainer, it should take no more than a minute or so for you to realize that this candidate does or does NOT know how to operate the vehicle and that his experience is either excellent, extremely limited or non-existent. If he stands and stares at the controls or takes an unusual or awkwardly long time to engage the controls, his candidacy should be labeled “new operator”. At that point, you can make a decision on whether you want to invest the time and effort to train that candidate from start to finish on that vehicle. My advice is to send them back to the agency because they do not know how to operate and they were less than fully honest about that when they agreed to apply for the job. You don’t need employees like that when on-boarding.
If the staffing agency wants your account, they will agree to do the initial training at their facility or offices BEFORE they send them to you for hands-on vetting and evaluation. This kind of partnering is what you pay a mark-up for when you use a staffing agency. It is not a huge additional cost for the staffing company and, in fact, it can often benefit the staffing company as operators who don’t work out and are not hired by your company can be placed at other companies that use the same staffing agency. Obviously, skills alone are not the only criteria that should be used in a decision to hire. So, if the candidate is experienced and does well on your hands on evaluation but also has a very strange or negative attitude in general, they probably would still not be the best candidate for your organization. They may have other employment qualifying issues, as well. In any case, demand the maximum effort from your staffing agency. You may want to consider involving the staffing recruiter or manager in your in-house training courses, too, so that they understand what you are doing and what goals and objectives you have in the process of staffing your positions. A really good agency will definitely agree to do these things, too. Don’t agree to working with an agency that says they have a recruiter who used to operate a forklift and knows how to recruit good operators………total BS. Unless he sees that operator on the forklift, there is no way to know that for sure. A resume or job application is no kind of verifiable proof. So, don’t accept substandard vetting from your agency.
If you do get the agency to agree to conduct the classroom training for candidates that they want to send over to you, tell them to send over the classroom training documentation to you with the candidate when the hiring candidate arrives to be screened, hands-on, on the forklift. You also need to periodically audit the staffing agency to keep them from becoming complacent and “short cutting” the classroom training session or making it into a 30 minute computer download lesson. I would review the training sessions monthly to make sure that they are doing this properly and honestly for you.
Cannot get the agency to agree to all this?
Get another staffing agency. Cheap bill rates mean nothing if you have to continually rehire or replace temps that don’t work out for you. In fact, it is more expensive to keep turning over temps from a low rate staffing service than it is pay a higher rate per hour to a staffing firm that sends the right quality and quantity of workers to you. Labor is the second most expensive input of the entire business so it is critical that labor cost is managed and controlled at every level and in every context.
Much of the successful retention of temporary workers starts with their ability to be successful on the job with the work they are asked to perform. If you are being sent candidates who are not able to meet your performance demands, they will be quitting on their own……….even before you have a chance to figure out what is going on with them.
Wage rate is one thing but not what retains workers. Those employees that feel there are no other redeeming qualities about their job except the wage will jump to another organization as soon as the new opportunity offers them a higher wage. If, on the other hand, the worker’s skills are matched properly with the job, they will find it easier to rationalize remaining with you since their tasks and activities have some intrinsic and meaningful satisfaction for them. If they are only working for you for the financial reasons then you will never be able to retain them and you should be honest about those workers and decide if that is what you want. Summarily, there are many non-wage factors that can cause a turnover or not with workers, of course, but placing an individual who is not qualified or cannot get qualified on a job is just eventually going to lead to them leaving the job.
22. Should my training include the use of operator restraint devices (e.g. seat belts)?
This brings up an excellent point. You need to make sure you have operator’s manuals on each and every piece of equipment you have in your facility. This is critical to compliance with the regulation. If they are not on them now, find them and get them on the vehicle. The presence of the manual should be part of the daily inspection. Replace those that are beat up or tattered and unreadable.
In creating a successful and comprehensive safety training program, the benefits listed above will present themselves as a result. Also, you will be implementing something that will contribute to the creation of an overall “safe working culture” that many organizations promote in big ways but are often failing when you pull the proverbial curtain back on them. A truly safe working culture will retain employees, attract the best available employees, lower operating and production costs, improve employee morale and many other benefits will follow. It takes work and commitment to create such a program but the initial work only has to be done once and then you have to maintain your creation.