Safety Tidbit #19 - Forklift Training: Who does it?

With their ability to move great weights and maneuverability powered industrial trucks (PITs) have become indispensable to move materials in the workplace.  And due to these same great characteristics, these vehicles are also extraordinarily dangerous.  Not surprising then that OSHA takes great care in their regulation on PITs. However, OSHA has an interesting anomaly in its powered industrial truck (aka forklifts) standard – Who does the training? 

According to 1910.178(l)(1)(i) - The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation.  Furthermore, this training must be completed before operation of the forklift on the job [1910.178(l)(1)(ii)].  OSHA does allow for employees who already have knowledge of the operation of the forklift but specifies that the driver must be evaluated [1910.178(l)(5)] to confirm their skill. 

OSHA specifies that training must 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 [1910.178(l)(2)(ii)].  There are two keys to this portion. First the standard requires two separate types of training (theory and practical) and, second, conducting a functional part in the workplace. 

OSHA also specifies minimum topics that must be taught or certified [1910.178(l)(3)].  And lastly, that the driver training must occur every three years [1910.178(l)(4)(iii)] or more frequently if the need arises [1910.178(l)(4)(ii)(A)-(E)].  And finally, OSHA even specifies what information they want on the certificate for the forklift operators [1910.178(l)(6)].

            So let’s review, OSHA regulates the frequency and content of their training. That forklift training must occur before the operation and retraining whenever something goes wrong (or nearly goes wrong). They mandate that the training must be both theoretical and didactic. So what’s missing???  Who actually does the training and evaluation?  OSHA only says, “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 [1910.178(l)(2)(iii)].”  So who is that?  What qualifications do they need?

How does the employer know they meet this requirement?  Fortunately, OSHA has a letter of interpretation from 2003 that sheds some light (or does it). The 2003 Letter of Interpretation says

 “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.”

So my question still stands who trains the trainer? And how do we really know if the trainer has the practical skills and judgment to operate the equipment and therefore to teach others?