Disclaimer: The 2020 SSG emphasis program is designed for owners and managers to ensure they are adhering to, and maintaining the technical elements of their OSHA compliance and safety program. Although some may be used for employee training, it was not designed as such
Full Video Script:
Welcome back to the 2020 Emphasis Program brought to you by Safety Consulting NOW. Which is, in my opinion, thee best online safety training platform out there. I may be a little biased, but not only do we continually add new and updated content, we conduct each training the same way we would if we were there at your site. This is a platform that’s written and produced by safety professionals, not an IT company or production crew. So I highly encourage you to check out the site by going to training.safetyconsultingnow.com where you can sign up for free, gain access to all of these emphasis trainings we’re doing each week, and sign up for the premium content that’s designed to facilitate effective, OSHA-required training within your specific operations. Now, this week we’re kicking off our first video on powered industrial trucks, also known as forklifts. And as I just alluded to a bit ago, the Safety Consulting NOW platform does have the classroom portion of this OSHA-required training, so sign up on there to gain access to that and many more. But, this particular video and this entire series is not intended to serve as a training. My objective in this emphasis program is to guide my clients in the detailed elements of their programs on items that may cause unsafe practices and OSHA citations. With forklifts being the #7 most cited violation in 2019 with 2,347 citations, this is certainly worth digging into. So let me quickly lay out the schedule so you know what you can look forward to. This video we’re gonna dive into Operation and Training, next week will be Maintenance, the following week will be Pedestrian-specific awareness, and then at the end of the month, we’ll wrap up with some pictures of common violations we see while we’re onsite at our clients.
So, right off the bat, I wanna make sure you understand that this topic directly applies to both construction and general industry clients. The perception is that it’s only applicable to manufacturing type environments, but as seen in Region 7’s regional emphasis program (which is where the majority of our clients are found), it states that October 1, 2019, until September 30, 2024 this Regional Emphasis Program is for Powered Industrial Trucks and Other Material or Personnel Handling Motorized Equipment in Construction, General Industry, and Maritime. The intent of an OSHA emphasis program is to encourage employers to take steps to address hazards, ensure facilities are evaluated to determine if the employer complies with all relevant OSHA requirements, and to help employers correct hazards, thereby reducing potential injuries, illnesses, and deaths of workers. You also need to understand that an emphasis program means that an OSHA inspector could be on your site for something completely unrelated to forklifts, but are expected to check your compliance with this program if they see these pieces of equipment are a part of your operations.
So, all of that said, this is a perfect segue for us to talk about the proper operations and training requirements for these big, metal beasts. First off, let me ask you: what’s your process for training on forklifts? The 1910.178(l) and 1926.602(d) standards require operator training and licensing as well as periodic evaluations of operator performance. The first thing you need to do is ensure you have an effective new hire training for any and all forklift operators that will be performing this duty. That means, even someone who operates on very rare occasions. It does not matter to OSHA if a particular employee operates one time per year or several hours each day. The operator training requirements must be followed regardless of the frequency. The standard also addresses specific training requirements for truck operation, loading, seat belts, overhead protective structures, alarms, and maintenance of industrial trucks. So ensure you provide a classroom portion or what’s we call a hands-on-classroom-style portion of your training that goes through these specific elements. Now, in my opinion, one of the most effective ways to address commonly asked questions is to answer those commonly addressed questions. Kicking it off, one of the questions we get asked all the time, is, “Jake, I’ve been operating a forklift at my previous employer for the past 10 years, do I still have to receive training at my new employer, especially since we had just received a refresher training less than 3 years ago? The answer to that question is a mostly “yes,” although OSHA technically says the answer is no. Let me explain. You are still required to receive site-specific training for forklifts at your new facility. Let’s break down a few important reasons why this is the case. The location of storage racks, docks, designated pedestrian walk-ways, type and style of forklift, blind spots, fuel source of the forklift, battery changing station location, and many more specific details of your new site are all reasons why this training needs to be conducted. Do they technically need to receive an updated operator license if they’ve been trained by a competent trainer? No. But also really you’re assuming the training they received from their former employer was solid enough. For this reason, and all of the site specific details, it’s our experience that you need to start from scratch with every new employee that comes to your site and operates your equipment.
So another common question we get related to this offsite training has to do with unions. That specific question goes something like this, “My employees receive training from the union on the use of forklifts. Will I have to provide any additional training?” When a worker reports to work, the employer must evaluate the employee to ensure that he/she is knowledgeable about the operation of the forklifts he/she will be assigned to operate. This evaluation could be as simple as having a person with the requisite skills, knowledge and experience observe the operator performing several typical operations to ensure that the truck is being operated safely, and asking the operator a few questions related to the safe operation of the vehicle. According to OSHA, if the operator has operated the same type of equipment before in the same type of environment that he/she will be expected to be working, then duplicative or additional training is not required. But I strongly encourage you to defer to my earlier response about the site specific nature of their new environment because these are specifics that are brought up in OSHA investigations after an incident or during an inspection.
Another question is “Is testing required.” No. The standard does not specifically require testing; however, some method of evaluation is necessary. So let me help you read between the lines. A test is not required, but some sort of written document that states the operator was evaluated is required. A drivers test and a written quiz can help facilitate and prove their competency. The NOW platform does provide the necessary training and the quiz, but onsite evaluation and operation is still required.
Next question: “Does OSHA require the employer to issue licenses to employees who have received training?”
No. The OSHA standard does not require employees to be licensed. But, most employers choose to issue licenses to trained operators so there is immediate proof of training. It also helps the employers stay within the 3 year recertification period because when an operator sees their training has expired on their license, they will help the employer stay reminded of their retraining needs.
Another one we receive is, “What type of records or documentation must I keep?”
The OSHA standard requires that the employer certify that each operator has received the training and has been evaluated. The written certification record must include the name of the operator, the date of the training, the date of the evaluation, and the identify of the person(s) performing the training or evaluation. At Summit Safety Group, we will specifically include the type of forklift (such as sit down or stand up) so we can show OSHA that multiple types of forklifts have been trained on.
Next one: “How long must I keep the certification records?”
Employers who evaluate the operator’s performance more frequently than every three years may retain the most recent certification record; otherwise, certification records must be maintained for three years.
And piggy-backing that question: “Is annual training required?”
No. An evaluation of each powered industrial truck operator’s performance is required to be conducted after initial training, after refresher training, and at least once every three years.
And speaking of refresher training: “How often must refresher training be given?”
The standard does not require any specific frequency of refresher training, but refresher training must be provided when:
1. The operator has been observed to operate the vehicle in an unsafe manner.
2. The operator has been involved in an accident or near-miss incident.
3. The operator has received an evaluation that reveals that the operator is not operating the truck safely.
4. The operator is assigned to drive a different type of truck.
5. A condition in the workplace changes in a manner that could affect safety operation of the truck.
So again, hearing these reasons for refresher training, I hope you can see more clearly why we always recommend retraining of employees that come from other facilities, regardless of their prior experience or training.
We also get this question: “Do I have to ensure that my operator’s are physically capable of driving a forklift?”
The new standard does not contain provisions for checking vision, hearing or general medical status of employees operating powered industrial trucks. The Americans With Disabilities Act (ADA) addresses the issue of whether employers may impose physical qualifications upon employees or applicants for employment. The ADA permits employers to adopt medical qualification requirements which are necessary to assure that an individual does not pose a “direct threat to the health or safety of other individuals in the workplace” provided all reasonable efforts are made to accommodate otherwise qualified individuals.
We also get asked about the allowed age of operators, so listen: It’s a violation of Federal law for anyone UNDER 18 years of age to operate a forklift.
Next question: “I have three different types of trucks in my workplace. Can I provide training on just one type of truck?”
If an operator will be expected to operate all three types of vehicles, then training must address the unique characteristics of each type of vehicle the employee is expected to operate. When an attachment is used on the truck to move odd-shaped materials, then the operator training must include instruction on the safe conduct of those operations so that the operator knows and understands the restrictions or limitations created by each vehicle’s use.
Second to last question I want to address: “I only have powered hand trucks in my workplace. Do the training requirements cover the operators of this type of vehicle? The operator walks alongside the unit while holding onto the handle to guide it.”
The answer is Yes. The use of powered hand trucks present numerous hazards to employees who operate them and those working in the area where they are used so they must also be trained on. If you wonder why they pose such a serious hazard, simply look at their capacity limits and the mere fact that most can carry upwards of 5,000lbs, shows how dangerous they can get and why training is needed.
Lastly, and we get this all the time: “I employ drivers from a temporary agency. Who provides them training – the temporary service or me?”
OSHA has issued several letters of interpretations on the subject of training of temporary employees. Basically, there is a shared responsibility for assuring employees are adequately trained. The responsibility for providing training should be spelled out in the contractual agreement between the two parties. The temporary agency or the contracting employer may conduct the training and evaluation of operators from a temporary agency as required by the standard; however, the host employer (or other employer who enters into a contract with the temporary agency) must provide site-specific information and training on the use of the particular types of trucks and workplace-related topics that are present in the workplace. So in other words, regardless of the temp agency providing this training, the host employer must train on the site specific elements I keep trying to make glaringly obvious.
Now look, I hope this serves as a pretty significant guide for you on how you should be training your operators. There are many more questions we could get into but we still have 3 weeks left on this topic, and I’m hopeful we’ll continue to answer these for you as we go. If you have any questions on this material, please reach out to your SSG safety consultant, reach out to us in general at firstname.lastname@example.org, call us at 417-823-SAFE, or you can reach out to your digital safety consultant on the Safety Consulting NOW platform. We’re doing great things here at SSG and we’re happy to have you on this journey with us. For Summit Safety Group and Safety Consulting NOW, I’m Jake Woolfenden and I’ll see you next week where we’re gonna dive into the requirements of your forklift maintenance program. I’ll see you in there.