Forklift regulations of the Occupational Health and Safety
Administration require "only trained and authorized operators shall be permitted to
operate a powered industrial truck. Methods shall be devised to train operators in the
safe operation of powered industrial trucks."
The traditional complaint with regard to the standard has been the lack
of definition as to what constitutes a "trained" operator and the type and scope
of "methods"to be devised.
In the grand tradition of "be careful what you wish for,"
OSHA issued new forklift regulations at the end of 1998. They are substantially more
specific with regard to what is required under the standard, how it will be evaluated by
their compliance officers, and what the associated documentation requirements will be. The
focus is certainly not misplaced given the fact that powered industrial truck operations
account for over 100 fatalities and 38,000 injuries annually.
The most significant features of the new standard are:
Employers will be required
to provide initial and refresher training to operators of their powered industrial trucks,
with the frequency of the refresher training clearly reflecting the knowledge, skills and
demonstrated ability of the industrial truck operators.
Every operator or
potential operator of a powered industrial truck, including part-time, seasonal or
substitute, must be trained before being allowed to operate a powered industrial truck.
This also includes "experienced" operators who have operated powered industrial
trucks for other employers.
The training must be
conducted by an individual with the necessary knowledge, training and experience not only
to train operators but also to judge their competency. An experienced operator does not
qualify as a trainer unless he has received specific training in how to teach or train and
in the theoretical hazards inherent in powered industrial truck operation.
The content or scope
of the required training is not significantly changed from the existing standard.
The employer must
provide a combination of classroom instruction and practical "hands-on"
training. Use of a video or CD-ROM by itself will not be deemed adequate.
Employers will have
to do an operational performance evaluation of each operator a minimum of every three
years. If this operational performance evaluation indicates any deficiencies, retraining
specific to those deficiencies will be required.
Existing operators
must be evaluated in terms of their understanding of theory and practices and must receive
an operational performance evaluation conducted by a qualified instructor.
Under the standard,
you must be able to document that your operators have successfully demonstrated their
ability to safely operate their powered industrial truck.
If you hire an
operator who has been trained under the new standard, you will be required to have
documentation of the training completed, certification of successful completion and
contact information for the individual who conducted the training.
The training you
provide cannot be a "canned," one-size-fits-all, general program. It must be
specific to your site and operations and to the equipment being operated.
(Editors Note: Donald R. Rung is vice president for technical field services
for Lumber Insurance Companies in Framingham, Mass. He may be reached at (508) 872-8111.)