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.