Every powered industrial truck operator’s performance must be evaluated at least once every three years. These evaluations could be conducted more frequently, of course.
A common misconception is that operators must be given refresher training every three years, but the regulation actually specifies an “evaluation of the operator’s performance.” Of course, if the operator is observed doing something unsafe, refresher training may be needed.
This evaluation requirement raises a number of questions, from who may conduct them to what the evaluation should cover.
All training and evaluations must be conducted by someone with the knowledge, training, and experience to train operators and evaluate their competence. This includes the three-year evaluations. Although supervisors should continually watch for unsafe driving habits, they probably aren’t qualified to conduct the formal evaluation.
The evaluator should watch the operator performing job functions such as approaching, lifting, carrying, and depositing loads. There is no duration required, but the evaluator should ensure that the operator follows all safety rules. Violations might include raising or lowering the tines while moving, driving too fast, not wearing a seatbelt, placing hands outside the running lines, or failing to remove a defective vehicle from service (e.g., headlights not working).
One consideration is whether operators should be informed when the evaluation will be conducted, since they might be more diligent about following safety rules compared to a “surprise” evaluation. Of course, during evaluations, the operator must also be questioned on their knowledge of safety rules, but the observation portion could come first.
If the evaluation reveals unsafe operating habits, OSHA requires refresher training. This training may be limited to relevant topics, with a focus on topics relevant to the problems observed.
The regulation also requires evaluating the effectiveness of training, and that applies to refresher training as well. After any refresher training, the operator should be observed to ensure that he or she is actually applying the information delivered.
Evaluators should also consider if training is the solution. If the operator understood the safety rules, but violated them anyway, then refresher training probably won’t prevent future violations. The root cause or motivation for breaking the rules must be addressed, whether it was pressure to work faster or an attitude that the safety rule wasn’t necessary.
The OSHA regulations provide the basics, but OSHA has a lot of guidance in the form of interpretations and compliance directives to explain how the agency will enforce the regulations. Not only are these documents found in the J. J. Keller® SAFETY MANAGEMENT SUITE for an easy-to-find reference, but our compliance experts can help dispel any misconceptions. If you have any questions, send them in through the Expert Help feature and you’ll have a private, secure and researched response — usually within one business day.