Is annual OSHA forklift driver training required?
No. Refresher training only needs to be conducted when operators are found to be operating unsafely, have been in an accident or near miss, receive a poor evaluation, or when there are changes in the workplace or type of truck. OSHA does, however, require an evaluation of each powered industrial truck operator’s performance at least once every three years.
Do we need to provide forklift operator training for each make and model?
No, not necessarily. But, you have to train on each “type” of truck. By “type,” OSHA is talking about basic differences - a sit-down rider truck vs. a stand-up truck, or an order-picker vs. a pallet jack. OSHA doesn’t intend that you have to give refresher training because someone starts using the same type of truck made by a different manufacturer. But, keep in mind that the operator will need instruction on any topics, such as the truck’s controls, that are different.
Would a written exam alone (i.e., without practical operation of the truck) suffice for the required 3-year operator evaluation?
The "evaluation" of "performance" required by the OSHA standard cannot be met by a written exam alone. A written exam by itself does not indicate whether the operator is operating the powered industrial truck safely. 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.
Does OSHA require powered industrial truck operators to have a valid driver's license?
Federal OSHA has no requirement that a forklift operator have a valid motor vehicle driver’s license. OSHA does require that every forklift operator be trained on the truck- and workplace topics in 1910.178(l)(3) and evaluated by a qualified trainer per 1910.178(l)(2)(ii) and (iii). Additionally, each operator’s performance must be reevaluated at least once every three years per 1910.178(l)(4)(iii). The employer must have a certification record documenting that the driver has successfully completed the training – that is the only “license” required by OSHA.
Is a vision/hearing test required before an employee may operate a forklift?
Federal OSHA's powered industrial truck standard does not specifically address vision/hearing requirements for operators. However, even though Federal OSHA doesn't specifically address it in the regulation, there are obviously some potential concerns and safety issues and these need to be evaluated in light of the specific operations.
In fact, OSHA has issued a letter of interpretation stating that an employer must determine if full vision is mandatory for the operations and advises that appropriate medical personnel be consulted. (Reference: October 20, 1976 OSHA Letter of Interpretation, which was edited in 2000.)
And, OSHA has issued other interpretations addressing both visually and hearing impaired potential forklift operators. In general, OSHA states that it considers physical impairments on a case-by-case basis. If the employer can show that a physically impaired employee would be a danger to himself and other employees when operating equipment such as a forklift, the employer has the right to not allow that employee to become a forklift operator. If the employer knew this fact, but allowed the employee to operate the vehicle, OSHA could cite under the General Duty Clause, which guarantees all employees a safe and healthful workplace – free of known hazards.
Additionally, the ANSI/ITSDF B56.1-2005 safety standard for low lift and high lift trucks states in Section 4.18 "Operator Qualifications" that operators must be qualified as to visual, auditory, physical, and mental ability to operate the equipment safely.
So, it is ultimately up to each employer (with a physician's guidance, if you choose) to determine if an employee can operate the forklift in a safe manner, both for himself and his coworkers.
Please note that, aside from OSHA, the Americans with Disabilities Act (ADA) may be involved as it prohibits employers from discriminating against individuals with disabilities in employment. ADA-related situations must be handled on a case-by-case basis. Employers may require as a qualification standard that an individual not pose a "direct threat," if this standard is applied to all applicants/employees. However, employers must meet very specific and stringent requirements under the ADA to establish that such a "direct threat" exists.
Like OSHA, the ADA requires that, when determining whether an employee can, with or without reasonable accommodation, perform the essential functions of the job, it is to be done in regard to a particular individual employee, and not require all employees who operate a forklift to undergo such. Such a blanket application may not be job-related and consistent with business necessity, which is an important consideration in evaluating ADA-related situations.
Who can train, evaluate and certify forklift operators?
In terms of who can conduct operator training and evaluation, OSHA requires in 1910.178(l)(2)(iii) that the trainers have the "knowledge, training, and experience" to train operators and evaluate their competence. The OSHA standard does not further define this requirement or set any specific forklift certifications.
However, OSHA discusses trainer qualifications in the preamble to the December 1998 final rule:
"OSHA has concluded that the final rule should adopt a performance-oriented approach to the qualifications of trainers and evaluators. As discussed above under issue 1, OSHA does not have the resources to evaluate and certify trainers and does not consider it necessary to do so. Trainers and evaluators with different backgrounds can achieve the level of ability necessary to teach and evaluate trainees. To meet these commenters' concerns, OSHA has eliminated the term "designated person" from the final rule and has instead described the knowledge, skills, or experience any trainer or evaluator must have under the standard."
OSHA also provides additional information in Appendix A of the Compliance Directive on the forklift driver training requirements, saying:
"How could an employer determine the qualifications of trainers?
An example of a qualified trainer would be a person who, by possession of a recognized degree, certificate, or professional standing, or who by knowledge, training and experience, has demonstrated the ability to train and evaluate powered industrial truck operators.
Can the person providing the training come from outside the company?
Yes, the employer may authorize a trainer from outside the company to conduct forklift certification, such as a training consultant or a manufacturer's representative. Nonetheless, the employer must have evidence that the operators have been trained in the required program topics. Some employers believe they must use an outside training consultant for forklift certification. However, an employer may utilize an employee who has the knowledge, training, and experience to provide training and evaluation."
And, in training and reference materials on the OSHA website, OSHA says:
"4. Who should conduct the forklift driver training?
All training and evaluation must be conducted by persons with the necessary knowledge, training, and experience to train powered industrial truck operators and evaluate their competence. An example of a qualified trainer would be a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has demonstrated the ability to train and evaluate powered industrial truck operators.
There are many resources available to the employer if he/she chooses not to perform forklift driver training himself. Truck manufacturers, local safety and health safety organizations, such as the National Safety Council local chapters, private consultants with expertise in powered industrial trucks, local trade and vocational schools are some available resources.
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 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.
5. If my employees receive training from an outside consultant, how will I know that these employees have been adequately trained?
Outside qualified training organizations can provide evidence that the employee has successfully completed the relevant classroom and practical training. However, each employer must ensure that each powered industrial truck operator is competent to operate a truck safely, as demonstrated by the successful completion of the training and evaluation."
In addition, there is an OSHA Letter of Interpretation that addresses the "experience" aspect of the trainer requirements:
"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. For example, 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."
If employees receive forklift driver training from an outside consultant, how does the employer know they have been adequately trained?
Outside qualified training organizations can provide evidence that the employee has successfully completed the relevant classroom and practical training. However, at 1910.178(l)(4)(i) OSHA says that each employer must ensure that each powered industrial truck operator is competent to operate a truck safely, as demonstrated by the successful completion of an evaluation of training.
In a letter of interpretation dated 10/01/1999, OSHA states: "As long as the employer has a reasonable basis to believe that the third-party trainer is qualified and has a program that meets the requirements of the standard, it can rely on that trainer to conduct the training and evaluation of employees and can certify that these employees have been trained. However . . . the employer may need to provide additional training on site-specific or truck-specific matters."
Operators must be trained on the local conditions and hazards prior to operating powered industrial trucks in the workplace. So while the operator may be competent to operate the equipment itself, the employer is still responsible for training on work-related topics, as noted at 1910.178(l)(3)(ii).
Do powered industrial truck training requirements cover powered hand trucks?
Yes, the use of powered hand trucks presents numerous hazards to employees who operate them and those working in the area where they are used. Therefore, training is required for powered hand trucks. The OSHA regulation at 29 CFR 1910.178(a)(1) indicates that the requirements, including those for training, cover motorized hand trucks.
Are golf carts and scooters covered under 1910.178?
OSHA does not have a specific regulation for scooters, golf carts, and other types of personal conveyances (that aren't intended to move, push, or pull materials). Most of these types of equipment are not covered under the OSHA Powered Industrial Truck (or any other specific) standard. However, OSHA still expects that this equipment to be used safely and could use the General Duty Clause to hold employers responsible for maintaining a safe workplace, including training operators on safe use.
The equipment manufacturer's operating instructions are usually a good resource. In addition, there are industry/ANSI standards for many types of equipment.
Are skid loaders covered under 1910.178?
In terms of the 1910.178 powered industrial truck standard, it depends on whether the equipment was designed primarily as earthmoving equipment). If it is primarily earthmoving equipment, then 1910.178 does not apply. See the following two OSHA Letters of Interpretation for additional information:
- 10/21/1999 - Earthmoving equipment is not covered by 1910.178; skid-steer equipment may be covered
- 03/07/2000 - Applicability of 1910.178 to earth moving equipment and skid steer loaders