Three-Year Check Up
Well, it was a long time coming, but on March 15, 1999 it finally arrived. OSHA’s new Powered Industrial Truck Operator Training Standard (PITOT) Standard 29 CFR 1910.178(l) brought to business and industry a significant amount of definition, clarity, and in some cases, even relief. For the few that were doing things properly to start with, it didn’t cause much of a ripple but for those that weren’t; it meant radical and immediate adjustment.
From the position of the end user, a standard that offer the degree of detail that this one does can have varying effects, depending on where it is implemented. It seems to work very well at a warehouse or factory site where there is a high degree of consistency in the types of machinery employed as well as the applications of use. However, construction sites and rental yards that may have scores of operators using a myriad of different types of powered industrial trucks (PITs) in constantly changing conditions, can find the standard a bear to work with.
Trainers Know Exactly What to Cover
From a trainer’s standpoint, OSHA’s PITOT standard is a blessing. Trainers now know exactly what must be covered in their classes and even what must be documented. No longer are they scratching their heads and wondering if the methods they devised to train operators are adequate.
Of course, one could argue that the previous wording said all that needed to be said: “Only trained and authorized operators shall be permitted to operate a powered industrial truck.” No problem there! It was the rest of it that was the problem. Anybody remember what the rest of it said? Say it with me now. “Methods shall be devised to train operators in the safe operation of powered industrial trucks.” Methods shall be devised? Could it be any more gray?
With the current PITOT standard, trainers and employers can now be confident that the training delivered is sufficient by covering all of the required items in the standard which mandates a detailed criteria including evaluated demonstration performed by the operator. Gone are the days of waiting for an accident investigation to reveal the adequacy (or inadequacy) of the “methods devised” for forklift operator training.
One of the more contentious issues within the standard is that of the qualifications of the trainer. The standard states that the trainer of PIT operators shall have the “knowledge, training and experience to train powered industrial truck operators and evaluate their competence.” This wording addresses the importance of what the operator is being taught as well as who is teaching it. And well it should. In the past, it was impossible not to have sat through training sessions with trainers who:
a) had great communication skills but no real knowledge of what they were talking about; or b) had great knowledge of the subject but not a clue as to how to convey it; or c) had an inability to deal with anyone that didn’t ‘get it.’ By injecting an expected level of competence on the part of the trainer into the standard, OSHA has effectively raised the training bar. Having the most experienced operator deliver the training based solely on operational experience simply doesn’t cut it any more, not that it ever really did. Plunking your operator(s) down in front of a computer monitor to sit through an interactive CD ROM does not do it either. Certainly, there is no denying that the experience of an operator or a good electronic training aid can add value to a PITOT class when used properly by a competent trainer; but on their own they are woefully inadequate. As for those that would argue that computers do not have “off” days like humans do, well, those people should try spending some time with my computer!
Site and Equipment-specific Training
Perhaps the most difficult aspect of the standard for business and industry to wrap their collective minds around has been the requirements to provide site and equipment- specific forklift operator training. This requirement has put a serious crimp in the style of how man employers previously handled their training, which was usually off-site. Unless an outsourced training provider could accurately reproduce the same conditions found in the employer’s workplace (load, terrain, storage and stacking of product, operating environment, etc.), the training performed would not meet the standard. Then there are the specific issues concerning the forklift: type classification, attachments, fueling, charging, etc. Even if the outside trainer managed to get around these obstacles, there is just no getting around the requirement for: “an evaluation of the operator’s performance in the workplace.”
Reputable outside training providers must make themselves familiar with the operating conditions and equipment at the site as well as any in-house policies and/or operating procedures before proceeding with any training. Then they must insert this information into the class and ensure that everyone involved understands it. This is no small task! Many employers choose the option of having one or several of there own people trained as trainers and then having them conduct in house operator training. This effectively addresses the issues involved with providing site and equipment-specific training because the employee who conducts the training on behalf of the employer may possess a level of familiarity with and understanding with the machinery and working conditions that no outside trainer could match. It also addresses the issue of the trainer’s competence, which is significant in light of the OSHA PITOT standard and therefore significant to employers.
Retraining and Recertification
Probably the toughest requirement for business and industry to comply with concerns operator recertification. There are a lot of employers out there who are, to say the least, unhappy about having to formally train, evaluate and certify all of their PIT operators. In the same vain, they can become absolutely rabid when they discover that they also have to re-evaluate them at least every three years! Re-evaluation or testing was never a required on a regular basis before the new standard was promulgated, and you can see why large employers may have a problem with this. It is conceivable some enormous outfit may spend huge gobs of time in ensuring that all of the operators get the required training, only to emerge from the task to find that they must now turn around and re-evaluate those same operators! In the past, re-training and/or re-evaluation were only done in the event of an accident and even then only in some cases. Now, the operator’s ability must be tested every three years, minimum, and even more often if the operator is involved in an accident or near miss incident attributable to operator error. A bright spot regarding the re-evaluation requirement from industry’s perspective is that it can be done on the job, so production does not necessarily need to be disrupted. However, even though the OSHA training standard only mandates a re-evaluation of the operator’s competence in operating the machine, it is also prudent to re-evaluate their theory knowledge with a short theory test as well, just to cover all the bases.
Results Are In
In summation then, to be able to assess how the regulations have affected the forklift industry, one must look at a snapshot of the industry before and after the regulation. Before the regulation, employers and trainers found it difficult to provide adequate PIT operator training, as there was no definition given by OSHA on the subject. In addition, no direction was provided regarding site and equipment-specific issues or on the competence of the trainer. The requirement for operator re-evaluation was non existent which gave rise to accidents and incidents out of ignorance and complacency. All of these factors combined to form an industrial culture of little or no training. If training was taking place, it was generally cursory or inadequate and delivered by somebody with no ability for the work at hand.
After the regulation, we have a PITOT standard that is reasonably clear and very comprehensive. There is still a bit of the negligent industrial culture out there that will fight every change tooth and nail simply because they can. The level of awareness that this standard has brought to business and industry across America regarding forklift safety and operator training has caused the most significant effect of all fewer people are dying. It’s working.
Director of Training
IVES Training Group
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