Spring 2002 IVES Update Newsletter

We'll be covering: Forklift operator recertification requirements. A question on forklift mechanics as operators. Accidents and more!

This Spring 2002 IVES Update Newsletter edition covers forklift operator recertification requirements, a question on forklift mechanics as operators, accidents and more!

Time’s Up! Have Your Operators Been Re-certified Yet?

Well, believe it or not, it has been three years since the OSHA training standard (29CFR 1910.178(l)) was passed into law. My how time flies when your having…um…fun, doesn’t it? For those of you that did all of your training right after the standard came into effect (March 1, 1999), this three-year mark carries some significance because like it or not, it’s time to re-certify your powered industrial truck (forklift) operators. For those of you that waited right to the bitter end and did your training at the compliance deadline (December 1, 1999 in most cases), you still have nine months.

Now strictly speaking, OSHA regulation states that operators must be re-trained whenever they are observed operating in an unsafe manner, cause an accident or near miss incident, are assigned to a different type of truck or working environment or whenever an evaluation reveals that additional training is needed. So, you may have already had to do some additional training in support of you regular training already but remember that an evaluation of the operator must be conducted at least every three years. That means that you, the instructor, have to see the operator in action at the worksite and assess their abilities.

Once again, strictly speaking an evaluation of the operator is all that the law requires at this three-year interval provided that they have been operating safely since being certified and nothing has changed with their equipment or environment. If you do…will be doing…or have done, what has been described here then congratulations, you understand the minimum requirements of the OSHA standard and are probably in compliance.

That being said, it is important to note that the requirements put forth by OSHA are the minimum requirements that the law allows. In our 22 years (wow, time really does fly!) we at Ives have learned that when it comes to matters of safety, taking a minimalist approach just isn’t good enough for us, and sometimes for OSHA either.

Keep in mind that Ives has been training equipment operators in excess of the current standard long before it was law. We advocated operator refresher training and re-certification every two years and many conscientious employers followed our advice…and still do. Which brings me to the point, if you want to just cover the minimum requirements of the OSHA training standard then you will probably get minimal results.

Our philosophy has always been to train people so that they remain safe and healthy, not so they can avoid the wrath of OSHA, although that’s a darn good reason.

For that reason, we strongly suggest that when the time comes for you to re-certify (or re-test) your operators, go the extra distance and provide them with some refresher training as well. Since these are experienced operators that have been previously certified, you will not need to go into the degree of detail that you probably did during the original certification class but you should review basically everything that you covered the first time around.

When Ives goes on site to re-certify operators, we always include at least an hour of refresher training in the classroom and even give the operators a written test. Our instructor will take his group to the actual equipment and do a walk-through of the pre-shift inspection, just to make sure that everybody still understands what is expected. Then, he will conduct a review of what is expected of the operators when they drive, this will focuses on operational technique and when everybody is happy, then it’s time to evaluate.

Performing the minimum evaluation of an operator during a re-certification will show you that they know what to do and how to do it. But, delivering some refresher training along with a test will ensure that they know why they should do the things that we train them to do, and as you may remember from your instructor training, that’s the most important part. The test will also be kept on file as documentation that the operator’s knowledge was tested as well … and that certainly can’t hurt.

For you minimalists out there, remember that the employer must constantly be working to identify potential hazards and take measures to eliminate them (remember the General Duty clause) and of course deliver training on how to deal with them. This rarely gets done on work sites where the level of training meets only the bare minimum. Getting back to regulatory compliance, we know that OSHA is going to look for evidence that minimum standards have been met in any and all situations. Realize though that they may also attempt to confirm that the level of training supplied by the employer was sufficient in relation to the conditions found on site. If it wasn’t then compliance may be an issue even though the letter of the law was followed.

In summary, minimum levels must always be met but it has always been our practice to deliver more than the minimum allowance to enhance safety and assure compliance. When it comes to matters like this, it’s better to err on the side of caution and do more than you need to. I know what side Ives is on here…what side are you on?

Ask Bob

Dear Bob,
Do the mechanics that service and repair the forklifts have to be certified as operators?
Wallula, WA

Dear Derek,
Yes. The OSHA regulations do not make any exceptions to the certification requirement of powered industrial truck operators based on the reason that they must operate the equipment. The only time a mechanic would be required to “operate” the equipment is to move it in or out of the shop or for “road testing.”These tasks could, and should, be performed by a certified operator. Failing that, the only time a non-certified operator would be allowed to operate a forklift is if he/she is under the direct supervision of a qualified instructor for the purpose of training.

OSHA may accept a non-certified operator operating a forklift if the situation could be considered an emergency, but the definition of emergency is open to interpretation.

Dear Bob,

I understand that to teach an individual (who is unqualified) and give them certification requires him/her to complete the applicable workbook, do the practical training, and then pass the written test and final practical test. If I am just doing re-certification (for an individual who is presently qualified), I am unclear as to what the individual has to do to maintain his/her qualification. I would appreciate any info you can give me, as I thoroughly enjoy instructing on the various types of forklifts.
Tony Miller
Comox, BC

Dear Tony,
The CSA requires us to provide “refresher training” for lift truck operators at intervals not exceeding two years. We are supposed to hit on everything that the original training did, but we don’t need to go as deep. Allow me to describe a typical refresher class.

The first thing I do is get everybody into a classroom of some description and review the theory material. Sometimes, I will bring some operator workbooks with me, but not always. I like to have something to give them so they can follow along with me. They won’t actually write in the books and I will collect them back at the end of the session. What I find works very well as a review tool is a set of overhead transparencies that we have. I find that if I go through each overhead, I will end up covering the contents of the book. Since it’s refresher training, I don’t need to go into the degree of detail that was necessary during the original training. So, I will review the theory material and cover off any applicable site-specific items.

Next, I will give them a theory test. We have an Operator Re-certification Notepad that comes with enough material to document eight operators. It includes theory tests, practical evaluation forms, wallet cards, and certificates. After they finish the test, I will grade it and review it with them. All of this takes from 1 to 1 1/2 hours.

From there, I will take the group to the machine for a refresher of the pre-shift inspection, general operating procedures, parking, and shutdown. Once everybody is happy with that, I can send everybody back to their jobs and begin practical evaluations one by one. I can get 12 to 14 people through in a day, depending on how many machines I have use of and how smoothly everything runs.

There you have it Tony. I hope I have been of some help.

Notes From the Field

Many times we find ourselves with too much to do and not enough time to do it. When it comes to schedule operator training in the workplace, the instructors are usually given the directive to get the training done—quickly, with as little disruption to the work place as possible. Some may feel that this directive is an impossible one; however, with careful planning and the cooperation of your safety committee and management team, an instructor can develop a training program that will cover all of the required elements to meet the current regulations.

A very real benefit of having an operator instructor on staff is the fact that the training he or she provides does not all have to be done in one day. Instructors may design their training program to address the theory portion and in-house safety policies and procedures in a seminar-type format. In this case, class size is limited only by the capacity of the training room. The practical training and evaluation of each operator can then be carried out in smaller groups, depending upon equipment availability and the individual instructor’s comfort zone. This practical training can be scheduled at times that will have the least impact on your company’s production cycle.

The key to providing a successful operator training program is in the instructor’s lesson plan. With a comprehensive lesson plan in place, the instructor can ensure that the operator training programs are effective and enjoyable. Some of the basic elements of a good operator certification program are:

  • Regulations – Review of mandatory regulations and your company’s policies & procedures.
  • Site Conditions – It is important that your operator candidates are made aware of the site-specific working conditions, such as areas of danger, surface conditions, pedestrian traffic, etc.
  • Understanding the Equipment – Type, components, capacity, etc.
  • Pre-shift Inspections – Walk-around check and operational checks.
  • Theory Training – Main parts, capacity, stability, general and specific operation, parking, etc.
  • Practical Training – Exercises performed by the operator in the field.
  • Evaluation – Theory test and practical operation testing.
  • Documentation – Record the name of operator and trainer, date of training, type of equipment used and retain the evaluation form and the theory test as proof.

Challenges Facing an Instructor
The workplace is very often a melting pot of ethnic and cultural groups. The primary language spoken on-site will usually be the language of the ethnic group with the most representation. The on-staff instructor may not be versed in the languages spoken by the operator candidates. How can they accomplish the training? Can they use an interpreter? Companies may hire interpreters; however, instructors should remember that the use of an interpreter will lengthen the time required to cover all aspects of the training. If you use an interpreter, be sure to limit your class size accordingly. Your interpreter must be a non- biased individual, preferably with no personal connection to any of the operator candidates.

Another common situation that instructors can find themselves in is one in which an individual in the class experiences difficulty in reading. In cases like these, instructors must try to convey information as visually as possible and may have to verbally administer the Operator Theory Test to the operator candidate on a one-on-one basis. Then, the instructor can make a decision as to the candidate’s ability to perform his duties in a safe and efficient manner based on the demonstrated practical operation of the equipment.

When faced with unique situations, involve your safety committee, the immediate supervisor and you (the instructor). With input from everyone concerned, a solution can usually be found. Whatever the decision is on how a given situation is to be handled, document it! Always put the details in writing, with a copy for your training file and one for the operator’s personnel file kept by the employer. Never forget the golden rule: if it isn’t documented, it didn’t happen.

What’s Your Instructor IQ

Q – During a practical training session, the instructor notices the operator do something wrong. When it becomes appropriate, the instructor approaches the operator to ask him some things about it and see if he can lead the operator to the problem. After the operator success- fully identifies the problem and the solution, the instructor tells the operator to park the equipment, satisfied that the operator understands what he did wrong. Where did the instructor go wrong here?

A – The instructor asked for the truck to be parked without checking to see if the operator could demonstrate proper operation. After verbally addressing the problem with the operator, the instructor should have had the operator repeat the task to ensure that task could be properly demonstrated.

You Won't Believe This!

Thieves Use Forklift to Steal ATM
CALABASAS, UNITED STATES — Burglars used a forklift to break into a supermarket and steal an automatic teller machine (ATM) on December 9, 2001. The Los Angeles County Sheriff’s Department told the Los Angeles Times that the robbery occurred about 4am at Gelson’s market. The ATM was not bolted to the floor. The amount of cash stolen was not revealed.

Parking Enforcement Goes to New Heights
Parking inspectors in South Africa took enforcement to new heights by employing a forklift to remove illegally parked cars in Cape Town.

New Use for Forklifts
UNITED KINGDOM — In May 2001, a farmer was jailed for two months after using his forklift to flip three council vehicles into a hedge. Council officers had refused to leave his property after serving enforcement notices to remove pallets.

Limited Equipment Capacity
WASHINGTON STATE — In October 2001, a forklift operator tried to claim compensation from his former employer, saying injuries sustained in a 1995 accident meant he could have sex only twice a month. The case was dismissed. (Always stay within the capacity of your equipment. – Ed.)

Forklift Driver Fined for Breaking Wind
AUSTRALIA — In June 2001, a forklift driver was fined for breaking wind near a police officer in an Australian police station. The convicting judge said his actions were “intended to cause anger and disgust.” (It’s hard to get experienced operators to break their old habits. – Ed)

Accident Report

Ontario, California – A 13-year-old was killed when she was impaled by the forks of a forklift driven by her father. According to police, the father was able to tell officers that he was driving the forklift and had positioned the forks all the way up. The 3,000-pound forklift then tipped as the man was turning the machine in a parking lot. “They (forklifts) can get pretty unstable in that position because it changes the center of balance,” a police spokesperson said. It is unclear whether the girl was on the machine. The forklift operator was in critical condition when admitted to the hospital, but was upgraded to fair, according to a nursing supervisor. (San Gabriel Valley Tribune)

Manchester, Iowa – A worker in a manufacturing facility was critically injured when he fell from a personnel platform on a forklift and struck his head. According to a spokesperson for the victim’s employer, the employee was working from the platform at a height of about four feet when the platform shifted, causing him to fall to the concrete floor. The spokesperson also stated that the lift had a protective railing, but that the platform was not attached properly. (Manchester Press)

Wayne, Michigan – A warehouse worker was crushed to death when steel plates fell from the forklift he was operating. According to a spokesperson for the local police department, he was driving a large-capacity forklift loaded with steel plates when he apparently got out of the lift to make some adjustments. Eight 10’X20’ steel plates, each weighing 13,000 pounds, then fell off the forklift and crushed the man. The accident is under investigation. (Romulus Roman)

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