Top 3 forklift violations relate to training

Powered industrial trucks (PITs) include forklifts, powered pallet jacks, stand-up rider lift trucks, order pickers, and the like. In fact, that’s one major compliance issue — some employers fail to train operators on all the types of PIT equipment they operate. Even powered pallet jacks require training under 1910.178, and that training must be equipment specific.

You don’t necessarily have to train each operator on every powered pallet jack made by different manufacturers, but OSHA does prohibit allowing an operator who only has forklift training to operate a powered pallet jack without additional training — the training must be for each “type” of equipment.

A closer look at the violations

In fiscal year 2023, the top three PIT violations were related to training:

1. 1910.178(l)(1)(i) Competency training: 452 violations.
   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 specified in this paragraph (l).
2. 1910.178(l)(6) Certification of training: 314 violations.
   The employer shall certify that each operator has been trained and evaluated as required by this paragraph (l). The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation.
3. 1910.178(l)(4)(iii) Regular evaluation of operator’s performance: 268 violations.
   An evaluation of each powered industrial truck operator’s performance shall be conducted at least once every three years.

Training includes both truck-related topics and workplace-related topics, which are outlined in paragraphs (l)(3)(i) and (ii) respectively. Training must be a combination of formal instruction, such as a lecture or computer-based learning; practical training, such as demonstrations performed by the trainer and practical exercises performed by the trainee; and an evaluation of the operator’s performance in the workplace. The operator’s performance must be evaluated at least once every three years.

Refresher training must be conducted when:

• There’s an accident or near miss,
• The operator is observed operating unsafely,
• The operator is assigned to drive a different type of truck,
• A condition in the workplace changes in a way that could affect the safe operation of the truck, or
• An evaluation reveals deficiencies.

Employers must certify that the operator has been trained and evaluated. Documentation must include the operator’s name, dates of the training and evaluation, and the name of the trainer/evaluator.

Who can provide training?

OSHA says the trainer must have the “knowledge, training, and experience” necessary to conduct the training. This can be obtained in various ways:

• Through years of operating a PIT and knowledge of safe practices and OSHA regulations pertaining to the operation,
• Going to a “train-the-trainer” or similar course, and/or
• Some combination of experience and training.

The only specific criteria OSHA lays out is found in a 2003 letter of interpretation. It says that the trainer must have at some point operated the type of equipment they are training potential operators on, so that they can provide adequate instruction to trainees on how the equipment works, feels, etc.

Employers may designate someone they feel comfortable with as the trainer. This may be someone within the organization or a third party.