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Great information! I knew about each of those myths except for the "evaluation" specifics. It is nice to have the info. in one location for easy reference and the ability to pass it along to employers.
ReplyDeleteCurtis,
ReplyDeleteGood coverage of the 3 areas where confusion tends to creep in regarding PIT training. As a court recognized forklift expert, I too am called upon to review PIT training documents to provide an opinion on compliance. Class 3 training (walkies) is a common area that gets overlooked. Also, many companies are under the assumption a training class is required every 3 years, which is not except as you outlined above. One other thing that I would add is that the evaluation must be done in the workplace, not at a forklift dealer or unrelated location, on the same piece of equipment that he/she will be operating or one equipped just like it, and on each type if more than one is used. Any difference in operator position, power type, or position of controls will require a separate evaluation. The operator must demonstrate proficiency moving loads in a manner that duplicates normal use, not running around cones in the parking lot.
The evaluation is to be hands on the machine your will be expected to operate; in the enviornment you will be expected to manage; and doing the tasks you are expected to handle, is that what is ment as evaluation as opposed to training?
ReplyDeleteBill Willings
Yes, Bill. The adequacy of the operator training must be confirmed by an actual evaluation of the operator's performance in the workplace, as you describe. This is necessary to determine that the operator can effectively utilize all the training to drive safely in the workplace.
DeleteCan you please describe a powered industrial truck. And does this also go for zoombooms and manlifts to be evaluated and documented every 3 years instead of paying for a refresher? Is this valid here in Canada? Thank you
ReplyDeleteThere are 7 classes of powered industrial trucks regulated by OSHA in the USA. Not sure what Canadian standards address. Here is the list:
DeleteClass I: Electric Motor Rider Trucks
Class II: Electric Motor Narrow Aisle Trucks
Class III: Electric Motor Hand Trucks or Hand/Rider Trucks
Class IV: Internal Combustion Engine Trucks (Solid/Cushion Tires)
Class V: Internal Combustion Engine Trucks (Pneumatic Tires)
Class VI: Electric and Internal Combustion Engine Tractors
Class VII: Rough Terrain Forklift Trucks
Also, here is a link to the different types of powered industrial trucks covered by the OSHA standard - with pictures: http://www.osha.gov/dcsp/products/etools/pit/forklift/types/classes.html#class1
As you can see, manlifts / boomlifts are not included. Hope this helps.
yes it does. thank you curtis. i got my card today and my mid- term evaluation is dec 2013. and expires june 2015. does this mean i have to pay for the course all over again in 2015, or do i just get re- evaluated again at that time.
DeleteThe OSHA regulation only requires an evaluation every three years. Assuming there are no applicable events (accident, near miss, unsafe operation, change in equipment or work conditions . . .) refresher training would be optional.
DeleteBruce, in Canada we are required to go through retraining on a full blown scale at least every 3 years. This would mean theory and evaluation.
DeleteCan you tell me if the shopping cart tugs fall under the 1910.178 standard. They operate in a similiar fashion to the Class III powered hand trucks, but I cannot find any determination, one way or the other. Thank you
ReplyDeleteGood question. While my initial reactionm is to say yes, these are a class II truck, I have never trained with a grocery store that uses these shopping cart tuggers, so I have no first-hand experience. I will put the word out to see if anyone in the grocery store industry can give us some guidance as to what they do.
DeleteI am just following up to see if you have gotten any feedback about the shopping cart tugs
DeleteThanks
Lisa.
DeleteI put the question out there on Lindedin to get responses from others, and the overwhelming consensus was that no, the cart mover is not a powered industrial truck because it does not meet the definition provided by OSHA (a PIT moves "materials"). However, they all agree that because of the potential risks not just to the workers, but also pedestrians and vehicles in the parking lots and stores, the operators do need to be trained and evaluated on the operation of that equipment, and some suggest the manufacturer could assist you with materials and guidance. I guess the only step left for you is to contact your local OSHA office to ask their opinion, as I am sure that will vary from office to office. Best wishes.
Excellent information and a good review of what is required.
ReplyDeleteI have already passed on this information to my team. Great information. Was not aware of the evaluation requirement and exactly how it was supposed to be documented. Thanks for the info!!!!
ReplyDeleteSam
Curtis, thanks for the information! I always thought as many do every three years the refresher training was adequate. I went back and studied the 1910.178 regulations again for better clarity. Thanks! Wayne
ReplyDeleteCurtis... Great info. I am preparing to teach a PIT class next week. This will be my first class - YIKES!!
ReplyDeleteMarty
Are there any requirements for trainers to be qualified for certifying employees to drive forklifts? Is it okay to just buy a package with a video and set up an obstacle course; or does the trainer need to go through a train-the-trainer course. Would the trainer need to go through recertification every 3 years?
ReplyDeleteTim,
DeleteOSHA has concluded that the final rule should adopt a performance-oriented approach to the qualifications of trainers and evaluators. Here is the actual standard:
1910.178(l)(2)(iii)
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.
As written in the final rule, any employee with the requisite knowledge, training, and experience could conduct the required training (both initial and refresher) and evaluations. An employer could also employ one or more such persons, or could contract with an outside training organization to conduct the required training and evaluation activities. 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. 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. There are no refresher requirements to be a trainer, either. Hope this helps.
The blog focuses on the rules for federal OSHA, which are adopted by most state-plan OSHA programs. However, a reader in Michigan points out the best practices he follows, as well as differences in the MIOSHA rules, pasted below:
ReplyDelete1. MIOSHA Rule 2154(5): A permit to operate a powered industrial truck shall be valid only with the employer who issued the permit, and the permit shall be issued for a period of not more than 3 years and shall be consistent with subrule (2) of R 408.12151. Note: 12151(2) reads “An employer shall assure that an employee assigned to operate a powered industrial truck shall meet the minimum requirements stated in this rule and shall be retested not less than every 3 years”. In Michigan, evaluation and testing is required.
a. Not a big deal, but testing denote something more than simply watching a driver operate his truck. Refresher training and re-evaluation of the drivers aptitude and proficiency is an appropriate best practice for companies who are serious about safety excellence.
2. Rule 2154. (1) An employer shall provide the employee with a permit to operate a powered industrial truck only after meeting the requirements prescribed in R 408.12151, R 408.12152, and R 408.12153.
a. This is different language than the Feds use and means that the employer is required to issue a card to the driver. Most employer then require their drivers to carry the card at all times.
3. Rule 2154(3): A permit shall be carried by the operator or be available upon request by a department representative at all times during working hours.
a. In Michigan, most employers require their forklift drivers to carry a card-permit with them. But I agree with your suggestions for management to maintain comparable records.
4. Rule 2154(4): A permit shall indicate the type of truck an operator has been trained on and is qualified to operate.
a. This is an additional requirement that isn’t found in the Fed’s rule.
I would add that the re-training requirements would be required only for the deficiency observed etc. A complete training class is not required again. Although it may not be a bad idea depending on the severity of the observed violations.
ReplyDeleteHopefully I can get some help on clearing up a difference in regulation understanding between me & a counterpart. We are a manufacturing facility & we sometimes use golf carts to take parts to the other plants on our campus. Would the golf carts fall under the PIT training requirements.
ReplyDeleteCurious about this myself
DeleteThis has been a pain in my job for years. Clarification would be appreciated! Thanks!
DeleteSee the OSHA letter of interpretation at this link, particularly question #3: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29075
DeleteCurtis, can you clear up a “myth" for me. I've heard there is a requirement to have the manufactures PIT manual on the PIT at all times. Other have told me tht the manual must be just available to the operator so it can be kept in a control room. I've worked in several different states so this maybe different from state to state?
ReplyDeleteI am not aware of any federal OSHA standard that requires you to keep the operators manual on the actual forklift. However, you are correct that it must be available, because OSHA standard 1910.178(l)(3)(i)(M) states that the operator training provided include "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." Without having the manual available, you would have a hard time training on its content. If anyone is aware of a specific state-OSHA requirement to keep the manual on the forklift, perhaps you can let us know by replying to this blog post. Hope this helps. Thanks, Curtis
ReplyDeleteI have a question regarding this issue. Do aerial lifts apply to this training also?
ReplyDeleteThank You for your reply.
This particular standard (1910.179) does not apply to aerial lifts. There are other sections of the OSHA standards that address aerial lifts, specifically 1910.67 in general industry, and 1926.453 in construction. Hope this helps.
DeleteQutstion: Once an employee completes his/her PIT training,is there an expiration date? I understand and appreciate what you stated on the evaluation or refresher course on employees. This topic is interesting, but at the same time confusing.
ReplyDeleteThank you and I appreciate your response.
The training does not "expire", but the evaluation does have to be repeated every three years (or less).
ReplyDeleteHello all,
ReplyDeletei have a Question on forklifts.
Are fire extinguishers required on forklifts?
The Certification of PIT Operator Training & Evaluation form you have on website asks for the trainer and evaluator's name.
ReplyDelete#1 Does this mean the form can be used for the person conducting the training and/or also for the person conducting the refresher/evaluation? In other words, if training is conducted by a trainer, does he leave out info. under the evaluator's name section until evaluation is conducted by the employer?
#2 Or does this form require the trainer and the evaluator names for the same training date conducted, which is classroom, hands on etc.?
#3 Can the trainer be the evaluator for training conducted on same date?
I want to have as much proper documentation available for my recordkeeping.
Hope I make sense and I Thank you for your response!
What is the requirement for refresher training for electric lift trucks and battery charging.
ReplyDeleteI really enjoyed this post. You describe this topic very well. I really enjoy reading your blog and I will definitely bookmark it! Keep up the interesting posts!
ReplyDeleteIf an Employee working for a company with a location in Canada and US receives forklift training in Canada then is transferred to the US, does he/she need to be retrained in the US. Is the training accepted and meet the same requirements both ways?
ReplyDeleteThe U.S. based employer would have to evaluate the content of the operator's training they received in Canada, and cover anything that may not have been covered there that is required in the USA. Then, the U S employer would have to provide any hands-on training that may be required for the particular lift being used and worksite conditions, followed by an evaluation of the operator's performance in the workplace.
DeleteWhere must documentation of training be stored for companies with multiple sites? Must the training documentation be stored onsite where the operator works or is it acceptable to store training documentation for PIT operators in a central location?
ReplyDeleteAnywhere you want,, so long as you can access a copy and get it to OSHA in a timely manner during inspection. I have seen cases where an employer faxed the copy to a plant 500 miles away during inspection and all was okay. Hope this helps.
DeleteWhen completing an evaluation after three years, do I need to have the employee perform on each and every forklift model they are certified to use? My company has several types. Or does the one evaluation cover them all?
ReplyDeleteIf there are any differences whatsoever in the various trucks, then you would need to evaluate the operator on each type truck, at least in the areas where the differences exist. For example, you could evaluate the operator on truck A, and then evaluate them on the different aspects of truck B. Here is a link to a letter of interpretation that addresses this situation: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23724
ReplyDeleteWe've just received training from an outside source that told us we'd need re-training in 3 years. Thanks for busting that myth, and clarifying the 3 year re-evaluation process. He also told us we were out of compliance because we didn't have a fire extinguisher and strobe/warning light on our truck. I've looked around and can't find where either is a requirement. Can you please clarify OSHA's position on this? Thanks!
ReplyDeleteKeith,
DeleteMay want to find you a new source next time. The federal OSHA standards do not specifically require a portable extinguisher to be attached to a forklift. The standards do require that a suitable extinguisher be available within 50 feet of where flammable liquids are used (such as gas or diesel tanks used for refueling) so many employers mount one to the forklift(s) to ensure they always have one nearby. There is also no federal OSHA rule about having a strobe light on your forklift. But if the manufacturer put one on there when it was new, you must maintain it as a safety device. Hope this helps.
Thanks! I'll get them straight!
DeleteI would like to see a copy or example of an acceptable evaluation sheet or an example of acceptable documentation that OSHA would like to see when they ask to see a powered industrial equipment licensed driver credentials. Thanks
ReplyDeletePlease see the last paragraph of Myth #3 in this blog post. There you will see a link to a sample form for your reference. Thanks - CC
DeleteWith regards to the three-year evaluation process, Who would be qualified to perform the continuing evaluation? If we have two people each certified on two PIT units, could they document evaluation on each other every three years or do we need to hire a service to come in and perform the evaluation?
ReplyDeleteBrent. OSHA standard 1910.178(l)(2)(I)(A) simply states that all training and evaluation be conducted by "person(s) who have the knowledge and experience to train operators and evaluate their performance in the workplace." Based on that requirement, it could be feasible to have two operators evaluate each other IF they meet all this criteria. But I certainly would strive to mix it up a little and utilize an outside professional (perhaps from your FL vendor or safety consultant) conduct evaluations where possible. Great question.
DeleteI'm wondering about training for a specific facility. Our organization sent staff to a vendor for training. We have two different facilities where staff could operate a PIT. In order to be in compliance, does some sort of training/evaluation need to occur at each specific site, as well? The training was just conducted this week, so they wouldn't be up for evaluation until January 2018 otherwise, barring incident. Thank you!
ReplyDeleteFirst of all, make sure the training by the vendor is specific to the hazards in your workplace. 1910.178(l)(3)(ii) of the OSHA standard related to operator training specifies that part of the training address "workplace-related topics", including the following:
Delete(A) - Surface conditions where the vehicle will be operated;
(B) - Composition of loads to be carried and load stability;
(C) - Load manipulation, stacking, and un-stacking;
(D) - Pedestrian traffic in areas where the vehicle will be operated;
(E) - Narrow aisles and other restricted places where the vehicle will be operated;
(F) - Hazardous (classified) locations where the vehicle will be operated;
(G) - Ramps and other sloped surfaces that could affect the vehicle's stability;
(H) - Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust;
(I) - Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation.
Then the employer must evaluate the operator(s), which according to the last line of paragraph 1910.178(I)(2)(ii), requires "an evaluation of the operator's performance in the workplace". Unless the vendor has a place that is set up the same (or substantially similar) to your two workplaces, I would recommend you conduct (and document) an evaluation at your own site(s) too. It does us no good to have an operator drive around a few cones in a parking lot at the vendors site for their evaluation unless their real job is to drive around cones in the parking lot at their actual workplace. Hope this helps.
Typically, I have put together Powered Industrial Truck training programs with powerpoint slides, supporting manufacturers videos, written test and driver evaluations. If we build web based trainings which cover the content in the manufacturers videos; do we really need to show the videos and ensure they are kept onsite? Some are very outdated. Thanks for any clarification you can provide!
ReplyDeleteThe OSHA standard requires the following:
Delete"Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, 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."
As you can see, the formal (classroom) training lists interactive computer based training as an option. So if your CBT module covers all manufacturer's and OSHA-required info for your type(s) of forklifts, then you should be okay ditching the old videos.
Question: Do you think that UTVs fall under the powered industrial truck standard? Our city parks department uses John Deere Gators and Polaris Rangers to do work. I have heard from others at safety conferences that UTVs and ATVs would fall under this standard, and therefore require training and certifications to operate them. Do you know if this is true?
ReplyDeleteThanks for any help!
The OSHA FAQ's (found at https://www.osha.gov/dte/library/pit/pit_q-a.pdf) for the powered industrial truck standards at 1910.178 includes the following:
DeleteQ. What is the definition of a powered industrial truck?
A. Any mobile power-propelled truck used to carry, push, pull, lift, stack or tier materials. Powered industrial trucks can be ridden or controlled by a walking operator. Earth moving and over the road haulage trucks are not included in the definition. Equipment that was designed to move earth but has been modified to accept forks are also not included."
With that in mind, I usually advise that any UTV that is equipped or modified with a bed or similar configuration to haul materials (not tools, but materials) would fall under the FL operator training standards. But one used strictly for transporting a person from point A to point B is not. Of course, the employer should still provide training and evaluation of operators in the 2nd situation above because the equipment can be dangerous if not operated properly, but it does not fall under 1910.178. In fact, I have seen training materials for operators of UTV's available on the internet (some thru manufacturers, some thru training material providers).
I'm just curious if there is any regulation or rule making it mandatory that anyone using any type of powered equipment must also (or first have) a valid state driver's license? This recently came up in a work conversation and none of the involved parties had a definitive answer. Thanks
ReplyDeleteOSHA does not require a vehicle drivers license to operate a forklift
DeleteIf you have the situation where multiple operators are using a single forklift during a single shift, would you have each operator do a pre-use inspection? I know the regulations only call of an inspection for each shift, but my concern is an operator trusting another to do the inspection.
ReplyDeleteI guess that would depend on your operations. If all operators are properly trained and managed, I see no need for a redundant inspection. And if they are not? Then what makes us think the second operator (or third, or fourth . . .) will do the inspection?
DeleteThis comment has been removed by a blog administrator.
ReplyDeleteStill did not see a reference as to whether or not golf carts fall within the standard.
ReplyDeleteRead this OSHA letter interpretation at: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29075
DeleteGood to see so many comments on this topic for over four years! Now for my question regarding high reach order pickers where the operator platform is at the same level as the forks. These PIT's seem to be designed to allow for operators to safely travel at heights (provided they are qualified and with proper active fall protection) when traveling straight in dedicated aisles. This contradicts 1910.178(n)(7)(iii) which encourages an operator to only travel with the forks down. Manufacturer manuals only briefly touch this subject. One example states, "Travel with the platform close to the ground when outside of an aisle." Is there an exception to the OSHA requirement for high reach order pickers?
ReplyDeleteThanks!
John
No specific OSHA instruction on this subject, so follow manufacturer's instructions
ReplyDeleteCurtis,
ReplyDeleteHopefully this does not come across as a loaded question.
As a dealership, we have many Service Technicians who go in and out of a wide variety of businesses. We are big on ensuring compliance. The debate around what trucks the Technician is evaluated on, because, as technicians they understand the limitations of each type of truck and attachment added on, does not necessarily mean they have to evaluate on each type of truck they may encounter. Not to mention the changing environments they enter into on a frequent basis. Does OSHA have any guidance in this area. Whats the best practice here?
Thanks Curtis!