How to Comply With Powered Industrial Truck Operator Training Rules

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Materials Handling & Storage | Powered Industrial Trucks |

 

No provision of the OSHA Materials Handling requirements (Subpart N of the General Industry standards) generates more citations than the Powered Industrial Trucks (PIT) standard (29 CFR 1910.178(l)). And few parts of the PIT standard are cited more often than the provisions dealing with PIT operator training. Here’s an overview of the requirements and how to comply with them.

 

Click here for a Model Checklist you can use to ensure that your PIT operators are receiving the appropriate training.

Click here for Fatality Reports you can use to demonstrate the dangers of PITs to employees.

Click here for Safety Talks you can use to educate employees about PITs and the hazards they pose.

Click here for a Procedure you can use to evaluate operators’ skills and qualifications on an ongoing basis.

What Is a Powered Industrial Truck?

PITs include fork trucks, tractors, platform lift trucks, motorized hand trucks and other specialized industrial trucks powered by electric motors or internal combustion engines.  Compressed air or nonflammable compressed gas-operated industrial trucks, farm vehicles and vehicles intended primarily for earth moving or over-the-road hauling are not considered PITs and thus not covered by the standard.

 

Who’s Allowed to Operate a PIT?

It’s imperative to ensure that no employee operates a powered industrial truck (other than for training purposes) unless they’re competent to do so. How does an employee become competent? By completing and demonstrating proficiency in the required training.

Trainees are allowed to operate a powered industrial truck as part of their training as long as they’re under the direct supervision of persons who have the knowledge, training and experience to provide training to operators and evaluate their competence, and where  such operation doesn’t endanger the trainee or other employees.

What Training Do Operators Need?

Operator training consists 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.

The first stage of operator training is initial training, which has to cover 3 areas:

Area 1: Truck-Related Topics, including:

  • Operating instructions, warnings and precautions for the types of truck the operator will be authorized to operate;
  • Differences between the truck and an automobile;
  • Truck controls and instrumentation—where they’re located, what they do and how they work;
  • Engine or motor operation;
  • Steering and maneuvering;
  • Visibility (including restrictions due to loading);
  • Fork and attachment adaptation, operation and use limitations;
  • Vehicle capacity;
  • Vehicle stability;
  • Any vehicle inspection and maintenance that the operator will be required to perform;
  • Refueling and/or charging and recharging of batteries;
  • Operating limitations; and
  • Any other operating instructions, warnings or precautions listed in the operator’s manual for the types of vehicle the employee is being trained to operate.

Area 2: Workplace-Related Topics, including:

  • Surface conditions where the vehicle will be operated;
  • Composition of loads to be carried and load stability;
  • Load manipulation, stacking and unstacking;
  • Pedestrian traffic in areas where the vehicle will be operated;
  • Narrow aisles and other restricted places where the vehicle will be operated;
  • Hazardous (classified) locations where the vehicle will be operated;
  • Ramps and other sloped surfaces that could affect the vehicle’s stability;
  • Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust; and
  • Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation; and

Area 3: OSHA Requirements under the Powered Industrial Trucks standard.

Verifying the Effectiveness of Training

Simply delivering training isn’t enough to comply with the standard. You must conduct an evaluation to verify that employees actually understood their training. How? By requiring employees to demonstrate their ability to perform the necessary skills they need to operate a powered industrial truck.

For example, the illustration below shows a typical training course where the operator needs to drive around obstacles in order to place a load in a certain area. This course can test an operator’s handling of the equipment. The black lines are pallets, standing on-end. If the forklift knocks down a pallet or two, the operator loses points in this evaluation.

Refresher Training

You must provide refresher training in relevant topics to the operator when the operator:

  • The operator is observed operating the vehicle in an unsafe manner;
  • The operator is involved in an accident or near-miss incident;
  • The operator receives an evaluation that reveals that he/she’s not operating the truck safely;
  • The operator is assigned to drive a different type of truck; or
  • A condition in the workplace changes so as to affect safe operation of the truck.

In any event, you must evaluate all powered industrial truck operator’s performance—even if the above conditions aren’t present—at least once every 3 years.

Documenting of Training

You must certify that each operator has received the required training and evaluation in writing listing:

  • The name of the operator;
  • The date of training;
  • The date of the evaluation; and
  • The identity of the person(s) performing the training or evaluation.

The certification can be full-sized paper or a wallet-sized card, as long as all of the above information is included. It’s also important to note that the company rather than the training entity is required to certify the employee as approved to operate the PIT.

Conclusion

Note that OSHA doesn’t use the term “licensed operators” to describe operators’ qualification. All it requires is that operators be certified. However, as a practical matter, a company can issue internal licenses authorizing employees to operate a truck once they achieve the requisite certification.

 

 

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