Sunday, July 1, 2012

OSHA Training Myths Busted! - Powered Industrial Truck Operator Training and Evaluations

Over the years I’ve conducted numerous mock-OSHA compliance audits of safety training records, and have picked up on some common mistakes that are repeatedly made by many businesses and organizations. When I discuss these deficiencies with the clients, I tend to hear the same misunderstandings or “myths” about the OSHA regulations that lead to their mistakes. Because these same myths come up repeatedly, I’ve decided to discuss a few of them in this blog from time to time to help raise awareness of these erroneous beliefs, and to clarify what is actually required so others can avoid making the same mistakes (and avoid OSHA citations, too).

So today I will focus on three common “myths” related to the OSHA training standards for Powered Industrial Truck Operators.

Myth #1 - OSHA requires employers to conduct refresher training for their powered-industrial truck (PIT) operators every three years. 

FALSE! - OSHA standards do require initial training (formal “classroom” training and practical “hands on” training) and an evaluation (actual observation of performance) of all powered industrial truck (PIT) operators [see 1910.178(l)(2)(ii)]. The OSHA standard also requires additional refresher training and evaluations on pertinent topics be performed in special instances, such as when the operator is involved in an accident or near miss, observed operating unsafely, or there are changes in equipment or workplace conditions [see 1910.178(l)(4)(ii)]. But many employers also believe the OSHA standards require them to conduct refresher training for operators every three years, too. And that is where they can get themselves into trouble.

When you look closely at OSHA standard at issue here [see 1910.178(l)(4)(iii)], you will see it does not require refresher training every three years; it requires an evaluation of each powered industrial truck operator's performance be conducted at least once every three years. The evaluation is where the employer actually observes the operator performance in the workplace to ensure he or she is operating their PIT properly. Now I don’t have a problem if you want to provide refresher training every three years; knock yourself out. But be aware that if you only have a record of operator training conducted every three years to show an OSHA inspector instead of the mandatory operator evaluation that is required every three years, you are not in compliance with the OSHA standard referenced above. So always remember to conduct (and document) your PIT operator evaluations every three years.


Myth #2 - OSHA’s powered industrial truck operator training requirements do not apply to floor-operated battery-powered hand-lifts.

FALSE!  - The operator training standard applies to all classifications of powered industrial trucks, which includes not just sit-down rider forklifts, but also order-pickers, stand-up lifts, rough-terrain forklifts, tuggers, and the electric-powered mobile hand-lifts controlled by an operator who walks along with the lift (also known as a Class III powered industrial truck, see OSHA e-tool here for pictures).
 
I have audited many sites where the employer had meticulously trained and evaluated their operators of the traditional sit-down forklifts, but they were not aware the same rules also applied to the many employees who were operating hand-operated battery-powered pallet lifts. And I guarantee you that most (I hesitate to say all) OSHA inspectors are aware that the training and evaluation requirements apply to operators of these walk-behind battery powered lifts. So avoid problems with OSHA by setting up a specific program for training and evaluating your PIT operators who run floor-operated battery-powered hand-lifts.
 

Myth #3 - OSHA standards require powered industrial lift operators to carry a “driver’s license” to prove they are authorized to operate their lift.
FALSE!  -  The OSHA PIT operator training standard does require the employer to “certify” that each operator has been trained and evaluated [see 1910.178(l)(6) ]. The rule state that the certification must include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training and/or evaluation. There is no requirement, however, that requires the certification be carried by the operator.
 
Now I am not discouraging you from issuing a wallet-sized license to your PIT operators; in fact it can be a useful tool to spot-check for compliance on the floor.  But pay close attention to the requirements listed in the standard, because you must document ALL of the required details about the training and evaluation process. This can include in some instances three different names (the PIT operator name, the trainer name, and the evaluator name), as well as the date (or dates) the training and the evaluation were both conducted. That is a lot of information to cram onto a little wallet-sized card, especially if the training and the evaluation were performed by two different people on two different dates.

Very seldom have I seen wallet-sized cards that had all the required information, which sets the employer up for an OSHA citation if the wallet cards are the only documentation serving as operator certification. Furthermore, the cards tend to get lost or deteriorated over time, leaving you in a lurch during an OSHA inspection. So always utilize a full-fledged form to capture all the required information for each PIT operator (free sample certification form available here), and keep it on file in the office or someplace so it will not get lost or damaged, even if you issue forklift drivers licenses for your operators to carry.



So there is my two cents worth on the most common problems I see arising from misunderstanding related to the OSHA powered industrial truck operator training standards. I hope this helps clarify for some of you what is actually required, as opposed to some myth that you heard that could get you into trouble with OSHA.

Are there any other myths or misunderstandings related to PIT operator training and evaluation that you have come across that set up the employer for an OSHA citation? If you know of one and would like to share that information with our readers, or if you just want to make a comment about this blog post, please share your thoughts in the “comments” section below. And last but not least, please pass a link to this blog post along to others in your network who you think may benefit from this information.

39 comments:

  1. 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.

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  2. Curtis,

    Good 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.

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  3. 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?

    Bill Willings

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    1. 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.

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  4. Can 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

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    1. There are 7 classes of powered industrial trucks regulated by OSHA in the USA. Not sure what Canadian standards address. Here is the list:

      Class 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.

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    2. 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.

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    3. The 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.

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    4. Bruce, 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.

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  5. Can 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

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    1. Good 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.

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    2. I am just following up to see if you have gotten any feedback about the shopping cart tugs
      Thanks

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    3. Lisa.

      I 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.

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  6. Excellent information and a good review of what is required.

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  7. I 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!!!!

    Sam

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  8. 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

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  9. Curtis... Great info. I am preparing to teach a PIT class next week. This will be my first class - YIKES!!

    Marty

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  10. 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?

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    1. Tim,

      OSHA 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.

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  11. 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:

    1. 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.

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  12. 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.

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  13. Hopefully 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.

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    1. Curious about this myself

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  14. Curtis, 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?

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  15. I 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

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  16. I have a question regarding this issue. Do aerial lifts apply to this training also?

    Thank You for your reply.

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    1. 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.

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  17. Qutstion: 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.

    Thank you and I appreciate your response.

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  18. The training does not "expire", but the evaluation does have to be repeated every three years (or less).

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  19. Hello all,

    i have a Question on forklifts.

    Are fire extinguishers required on forklifts?

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  20. The Certification of PIT Operator Training & Evaluation form you have on website asks for the trainer and evaluator's name.

    #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!

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  21. What is the requirement for refresher training for electric lift trucks and battery charging.

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  22. I 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!

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  23. If 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?

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    1. The 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.

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  24. Where 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?

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    1. Anywhere 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.

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  25. When 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?

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  26. If 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

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