Train the Trainer 101: OSHA Forklift Certification Requirements

There are two rules I see consistently violated in utility operations. Coincidentally, one of them – fall protection on roofs and substation transformers – happens to be addressed in this issue’s Q&A.

The other is certification and licensing for forklift operators as required by OSHA 29 CFR 1910.178(l)(6), “Certification,” which states, “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.”

There is no language within the training rules that requires issuing of a license. When we use the word “license,” we are referring to a certificate that indicates that the holder is approved by the employer to operate the equipment. OSHA requires that the employer certify the training. License issuance is a means many employers use to show the employee is certified.

I know that training and certification of forklift operators is an issue because I frequently ask about it among colleagues, and also because it is one of the more frequently missed questions on the Certified Utility Safety Professional exam offered by the Utility Safety & Ops Leadership Network. OSHA only requires certification of two operator classifications: crane operators and operators of forklifts – or, as OSHA refers to them, powered industrial trucks (PIT). Other equipment operators must be qualified, and some classes of employees must be certified by the employer as competent, such as trench safety inspectors and signal persons under the OSHA cranes and derricks standard.

Crane and forklift operators are unique in that they are directed to have certain types of training, undergo classroom training, take a written exam and successfully complete a test of their skills. Both of these classifications also require a certificate of competency. The crane operator certificate has to be delivered by a third party. The forklift operator training can be delivered by the employer through a person qualified to deliver the training and designated by the employer. In utilities, many warehouse operations train their forklift operators, but the rule also applies to those field personnel who operate all-terrain lifts in construction lay-down yards. I know for a fact that most journeymen lineworkers are qualified to operate a forklift, but most of them are not properly licensed.

Effective March 1, 1999, under 1910.178 – one of those horizontal standards that applies to all workplaces – employers are required to have a training program specific to the type of forklift to be driven and the working conditions encountered. Employers must also evaluate the operator’s performance in the workplace and certify that each operator has successfully received the training needed. The certification must include the name of the operator, the date of training, the date of evaluation, and the identity of the person or people performing the training or evaluation. In addition, employers must conduct an evaluation of each powered industrial forklift operator’s performance at least once every three years. Employers must also conduct such an evaluation as well as refresher training if one of the following applies:
• Operator is observed operating the vehicle in an unsafe manner;
• Operator is involved in an accident or near-miss incident;
• Operator receives an evaluation revealing unsafe operation of the forklift;
• Operator is assigned to drive a different type of forklift; or
• Condition in the workplace changes in a manner that could affect safe operation of the forklift.

What vehicles are considered to be PITs?
The American Society of Mechanical Engineers defines a PIT as a mobile, power-propelled forklift used to carry, push, pull, lift, stack or tier materials. Powered industrial forklifts, often called forklifts or lift forklifts, can be ridden or controlled by a walking operator. Excluded from the OSHA standard are vehicles used for moving earth or over-the-road haulage.

How has OSHA changed its powered industrial forklift standard?
Previously, the OSHA standards required that only trained operators could operate powered industrial forklifts and that methods of training be devised. The 1999 standard requires employers to develop a training program specific to the type of forklift to be driven and the working conditions encountered. Employers must also evaluate the operator’s performance in the workplace and certify that each operator has received the training needed. This training is required before an employee is assigned to operate a forklift.

Where can an operator obtain the training required to become a certified forklift operator?
The employer is responsible for implementing a training program and ensuring that only trained drivers who have successfully completed the training program are allowed to operate powered industrial forklifts. An evaluation of each trained operator must be conducted during the initial training, at least once every three years and after refresher training. The training and evaluation may be conducted by the employer, if qualified, or an outside training organization. The PIT rules in 1910.178 contain all of the training requirements to certify an operator. Appendix A to 1910.178 provides guidance to employers about technical aspects of operation and stability to assist them with training. A guide for employer training of PIT operators can be found at www.osha.gov/dte/library/pit/trg_outline.html.

What type of training is required?
The training must be a combination of formal – such as lecture and video – and practical – such as demonstration and practical exercises – and include an evaluation of operator performance in the workplace. Forklift- and workplace-related topics must be included, along with the requirements of the OSHA standard. The specific training topics are listed in the standard.

Who should conduct the training?
All training and evaluation must be conducted by a person with the necessary knowledge, training and experience to train operators and evaluate their competency (see 1910.178(l)(2)(iii)). This may be the employer, another employee or another qualified person. The training and evaluation do not have to be conducted by a single individual, but can be done by several people provided each one is qualified. There is no certification required for forklift trainers. It is the employer’s responsibility to determine if a trainer is qualified to train operators. See July 23, 2003, OSHA interpretation letter to the U.S. Postal Service (https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25021).

Is refresher training required?
Refresher training is required when the operator has been observed driving in an unsafe manner, has been involved in an accident or near miss, has received an evaluation that indicates unsafe operation, is assigned to drive a different type of forklift or if a workplace condition changes that affects safe operation. An operator evaluation is required after refresher training.

What does “certified” mean?
The employer must certify that each operator has been trained and evaluated as required by the standard. The certification must include the name of the operator, the date of training, the date of evaluation, and the identity of the person or people performing the training or evaluation.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn has devoted the last 16 years to safety and training. A noted author, trainer and lecturer, he is director of safety for Atkinson Power. He can be reached at jim.vaughn@atkn.com.

Editor’s Note: “Train the Trainer 101” is a regular feature designed to assist trainers by making complex technical issues deliverable in a nontechnical format. If you have comments about this article or a topic idea for a future issue, please contact Kate Wade at kate@incident-prevention.com.