Safety Training Course Layout: Forward Slalom

Activity 1 --Forward Slalom:

· Trainer A at Position START/FINISH will:

o DEMONSTRATE DRIVING COURSE

o DEMONSTRATE INSPECTION OF TRUCK (Use company checklist if

available)

Operators must carefully inspect any forklift prior to use.

Any problems shall be reported. The Inspection Sheet provides a convenient reminder of items that must be checked. It also provides the necessary information for scheduling maintenance.

o DEMONSTRATE INSPECTION OF COURSE (looking for and removing any impediments)

o Data Plate: The data plate on each forklift contains all the basic capabilities and limitations of that forklift. Most forklift manufacturers have unique data plate designs, however most will have the same basic information on them. As an operator it is very important to understand all of the information given on the data plate. A data plate must have all the proper information listed and it must be legible.

o Discuss fork height—Forks must be low as possible when traveling except when entering or leaving a ramp. On those occasions, raise the fork only enough to be sure you have clearance. Whether your forklift is loaded or empty, always raise or lower the forks to not more than 6 inches from the floor before traveling. Never travel with the load in a raised position.

o Safe travel—Slow down and sound the horn at cross aisles and other locations where vision is obstructed. If the load being carried obstructs the forward view, the driver must travel with the load trailing behind

o Safety related to:

§ Mounting – 3 Points of Contact

§ Seat belts - The occupant restraints are designed to keep the operator in the seat and to help prevent any injuries that could result if a mishap occurs. You must wear the safety belt whenever you are operating the forklift.

§ Overhead Guard - The overhead guard is standard equipment from the manufacturer and must be included on the forklift. The overhead guard is not meant for roll over protection it is only intended to offer protection from the impact of small packages, boxes, and bagged material representative of the job application. The guard will not withstand the impact of a falling capacity load.

§ Hand placement—The operator must keep arms, hands and feet inside the forklift and away from the hoist mechanism.

§ Horn—All forklifts must be equipped with a horn. The horn is used as a warning device. The operator of a forklift must know where to locate the horn. They must test it to see if it is in good working condition before putting the forklift into operation.

§ Back-up alarm - The alarm is designed as a warning signal that the forklift is moving in reverse. This is to alert other forklift drivers as well as pedestrians of a potential hazard. This alarm does not relieve the forklift driver of the responsibility of looking in the direction of travel when backing. If your forklift is equipped with a backup alarm, it must be kept in operable condition.

§ Lights - Flashing lights or strobes are optional equipment on a forklift. They are designed to alert anyone around of the forklift’s presence. If the forklift has flashing lights, these must be kept in good working order. It recommended that lights be turned whenever the truck is in use.

§ Stopping/Starting (brakes, transmission, horn) - The parking brake is a safety device used to prevent the forklift from moving. It should be used whenever the operator stops the truck (momentarily or for extended periods) or leaves the truck. It is required that forks be lowered to the ground, controls be neutralized and brakes set when stopped.

· When a driver is going beyond 25 feet or does not have a clear view, additional requirements for powering down the PIT are to be followed.

o Trainer A at Position START/FINISH will provide verbal instruction and direction to begin driving portion as follows:

§ From the START/FINISH cone:

· Walk with driver to first cone assuring driver proceeds past the first cone on the right-hand side (as illustrated in RED)

· Provide instruction on how to use inside front tire as point of reference for making turn

· Allow driver to continue to slalom through remaining cones to Trainer B at Position 1

§ Trainer B at Position 1 will:

· Visually guide driver to STOP position (Confirm at STOP position that emergency brake is set, forks are lowered and the vehicle is neutralized and shut down for the safety of the instructor.) (You may want to discuss shutting down if stopped for long periods)

· Discuss Doorways / Passageways: STOP-HONK-GO

· Provide instruction on performing reverse slalom (as illustrated in BLUE) from Position 2

· Trainer B will provide feedback if needed

National Safety Compliance also provides training materials such as DVDs, Booklets, PowerPoints, Sample Checklist(s), etc. to aide with safety training for OSHA compliance.

Employee Safety Training/Sample Inspection Checklist

A powered industrial truck is defined as a mobile, power-driven vehicle used to carry, push, pull, lift, stack or tier material. Forklifts are one type of powered industrial truck used by many employers. There are many types and sizes of powered industrial trucks designed for different jobs. Many are named by the function they perform, such as high lift trucks, counterbalanced trucks, rider trucks and forklift trucks. Powered industrial trucks, also known as “forklifts” are used throughout many workplaces.

Statistics

Each year in the United States, nearly 100 workers are killed and another 20,000 are seriously injured in forklift-related incidents [BLS 1997, 1998]. Forklift overturns represent about 25% of all forklift-related deaths and represent the leading cause of fatalities involving forklifts. Injuries also occur when forklift trucks are inadvertently driven off loading docks or fall between docks and an unsecured trailer. Workers can also be injured when struck by a forklift, or if they fall while on elevated pallets. In most cases, both employee injuries and property damage can be attributed to lack of safe operating procedures, lack of safety-rule enforcement, and insufficient or inadequate training.

Follow OSHA Procedures

Federal law requires that forklift drivers be properly trained in and certified for operation of the forklifts they will be using. You can find these requirements in the Occupational Safety and Health Administration (OSHA) standard for powered industrial trucks 29 CFR 1910.178 and for forklifts used in the construction industry 29 CFR 1926.600 and 29 CFR 1926.602. The standard requires a written forklift safety program.

Training

It is an employer’s responsibility to ensure that every operator is competent to operate a forklift safely. Here are several possible steps to follow:

• After participating in a formal training program in the form of lecture, discussion, or classroom presentation, an operator must successfully complete a written evaluation.
• Forklift operators must participate in practical training which includes a demonstration of safe driving practices by the trainer. As part of the practical training, operators must also practice vehicle operation exercises.
• Operators must successfully complete a “hands on” performance evaluation.
• Employers must keep training records. A forklift operator must be re-evaluated at least once every three years to ensure they remain competent to operate a forklift safely.

Effective forklift training should, at a minimum, address these four major areas:

• General hazards that apply to the operation of all or most forklifts (including fuel and battery handling)
• Hazards associated with the operation of particular types of trucks
• General workplace hazards such as lighting and surface conditions
• Hazards of the particular workplace where the vehicle operates (including hazardous locations such as ramps, docks, narrow aisles, trailers, rail cars and closed environments)

The OSHA standard addresses specific training requirements for truck operation, loading, seat belts, overhead protective structures, alarms and maintenance of forklifts. Operator training should also address factors that affect the stability of a forklift – such as the weight and symmetry of the load, the speed at which the forklift is traveling, operating surface, tire pressure and driving behavior. Refresher training is required if an operator is found to be using the forklift in an unsafe manner, is involved in an accident or near miss, or is assigned a different type of truck.

Inspection and Maintenance

All forklifts should be examined before being placed in service. Daily examinations should be made and recorded in a written report or checklist. Your operators should take a few minutes at the beginning of each day or shift to inspect their forklift and complete the pre-inspection report or checklist.

Forklifts that are used on a round-the-clock basis should be examined before each shift. If any condition which adversely affects the safety of the vehicle is found, it shouldn’t be placed in service. Your employees should report any defects immediately for correction.

Forklift Safety Checklist

An effective forklift safety training program requires employer and worker compliance with OSHA regulations, consensus standards and equipment maintenance. Safety checklists, similar to the following sample, can help raise forklift safety awareness and safe practices and also help to prevent forklift accidents:

• Tires are inflated and free of excessive wear or damage.
• Forks and mast are not bent, worn or cracked.
• Load back rest extension is in place and not bent, cracked or loose.
• Overhead guard is in place and not bent, cracked or loose.
• Attachments (if equipped) operate OK and are not damaged.
• Forklift body is free of excessive lint, grease or oil.
• Hydraulic oil is full and free of leaks.
• Battery connections are tight.
• Covers over battery and other hazardous parts are in place and secure.
• Load rating plate is present and readable.
• Warning decals and operator's manual are present and readable.
• Seat belt or restraint is accessible and not damaged, oily or dirty.
• Motor runs smooth without sudden accelerations.
• Horn works.
• Turn signal (if equipped) operates correctly.
• Lights (head, tail and warning) work and are aimed correctly.
• Gauges and instruments are working.
• Lift and lower operates smoothly without excess drift.
• Tilt operates smoothly without excessive drift or "chatter."
• Control levers are labeled, not loose or binding and freely return to neutral.
• Battery charge level is OK while holding full forward tilt.
• Steering is smooth and responsive, free of excessive play.
• Brakes work and function smoothly without grabbing. No fluid leaks.
• Parking brake will hold the forklift on an incline.
• Backup alarm (if equipped) works.
  

Who should conduct the forklift operator safety training?

All training and evaluation must be conducted by persons with the necessary knowledge, training, and experience to train powered industrial truck operators and evaluate their competence. An example of a qualified trainer would be a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has demonstrated the ability to train and evaluate powered industrial truck operators.

There are many resources available to the employer if he/she chooses not to perform the training himself. Truck manufacturers, local safety and health safety organizations, such as the National Safety Compliance, private consultants with expertise in powered industrial trucks, local trade and vocational schools are some available resources.

Various Internet sites are devoted to forklift safety. Private companies who provide forklift safety training services, including videos and written programs, can be located on various Internet websites. Most videos can be either purchased. One important thing to remember is that simply by showing employees a video or videos on some aspect of forklift safety does not meet the full requirements of the OSHA standard. Site specific information must be conveyed as well as a method to evaluate the employee's acquired knowledge subsequent to the training.

Training requirements 1910.178(I) applicable to skid-steer loaders. Explain "experience" as it pertains to 1926.20(b)(4)

Question (1): Are the training requirements in §1910.178(l) applicable to skid-steer loaders used for earthmoving in construction? If not, what training requirements apply?

Answer: Title 29 CFR 1926.602(d) states:

Powered industrial truck operator training. NOTE: The requirements applicable to construction work under this paragraph are identical to those set forth at §1910.178(l) of this chapter.

Under §1926.602(d), employees engaged in construction who use equipment covered by 29 CFR Part 1926 Subpart O and the Powered Industrial Truck Standard (29 CFR 1910.178) must be trained in accordance with the requirements in §1910.178(l). However, §1910.178(a) states that the Powered Industrial Truck Standard does not apply "to vehicles intended primarily for earth moving...." Since skid-steer loaders are "intended primarily for earth moving," the training requirements in §1910.178(l) do not apply.

However, 29 CFR 1926.21(b)(2) states:

The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his [or her] work environment to control or eliminate any hazards or other exposure to illness or injury.

Therefore, under §1926.21(b)(2), the employer is required to train the skid steer operators so that they can recognize and avoid unsafe conditions. As a practical matter, such training needs to be comprehensive enough to ensure that the operator is fully capable of safely handling the equipment in the type of conditions he/she will encounter at the site. The amount of training necessary to fulfill the requirement may be reduced based on the extent to which the operator has acquired the necessary knowledge and skill from prior experience (see the answer to Question 2, below).

Question (2): Section 1926.20(b)(4) provides that only those who are qualified through training or "experience" are allowed to operate equipment. In this context, what does "experienced" mean? If a worker has operated the equipment a number of times in the past, does that automatically mean they are "experienced" for purposes of this requirement?

Answer: No. Title 29 CFR 1926.20(b)(4) states:

The employer shall permit only those employees qualified by training or experience to operate equipment or machinery. [Emphasis added.]

The term "experience" in this provision is used in conjunction with the term "qualified." Where an operator, through prior experience, has acquired the knowledge and skill necessary to safely operate the equipment, the operator may be considered "qualified by...experience" for purposes of this provision. However, a history of having operated the equipment by itself does not necessarily mean that the operator knows how to safely and competently operate the equipment. The provision requires the operator to be "qualified." If the worker has operated the machinery in the past but has not acquired the knowledge and skills necessary to safely operate the equipment, the experience is not sufficient to make the employee "qualified."

Fall Protection on an elevated platform: body belts or harnesses?

Question 1: In regards to the use of fall arrest equipment and the use of body belts, do OSHA regulations require that a body belt be attached to a lanyard and used to protect personnel against falls from elevated "operator-up" high lift truck platforms, or do the standards state that a 5-point harness must be worn as a part of a fall arrest device?

Response: OSHA's powered industrial trucks (PITs) standard, contained in 29 CFR 1910.178, does not have provisions that require either the use of a body harness or safety belt to protect personnel against falls from elevated platforms. However, in the absence of a specific standard, OSHA can enforce Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act) -- which requires employers to protect employees from serious recognized hazards. Industry consensus standards, such as ASME B56.1-2000 Safety Standard for Low Lift and High Lift Trucks would be taken into consideration by OSHA when determining whether a hazard is "recognized" and that there is a feasible means of abating such a hazard. Section 4.17.2(c) of ASME 56.1-2000 requires that whenever an operator-up high lift truck is used to elevate personnel, restraining means such as railings, chains, cable, body belt(s) with lanyard(s), or deceleration devices, etc. are in place and properly used. Although the ASME standard calls for the use of body belts, OSHA strongly encourages employers to use body harnesses in place of body belts. You should also be aware that, as part of a rulemaking to revise Subpart D of 29 CFR 1910, OSHA has proposed the inclusion of a fall protection requirement that would apply to work platforms used in conjunction with powered industrial trucks. See the No. 68 Federal Register 23528 (May 2, 2003). A copy of the relevant portion this Federal Register is enclosed.

Question 2: Can OSHA give me information on fines and the circumstances surrounding the fines, if a plant is found to be violating the fall arrest guidelines set forth by OSHA?

Response: During the course of an inspection, if an employer is found to expose his or her employees to fall hazards which could result in serious injuries, citations would be issued along with proposed penalties. The amount of proposed penalties varies, depending on the type of violation: Willful, Serious, Other-Than-Serious, Failure-to-Abate, and Repeat; and on the employer's size, good faith, previous history of violations, and the gravity of the violation. For example, OSHA may propose a penalty of up to $7,000 for each serious violation, whereas penalties for each willful violation may range from $5,000 to $70,000. Our penalty calculation procedures also give consideration for any employer with 250 or fewer employees. Normally, a reduction of 60 percent may be applied to penalties if the employer has 25 employees or fewer; 40 percent if the employer has 26-100 employees; and 20 percent if the employer has 101-250 employees. Although no reduction for size is applied if an employer has more than 250 employees, the employer may still be accorded up to a 10 percent reduction for a lack of previous violations, and a 25 percent reduction for "good faith," which mainly depends upon the effectiveness of the employer's safety and health program. When these three factors are combined, it is possible for the smallest employers to receive up to a 95 percent reduction in the initial monetary penalty. The enclosed OSHA 3000 publication, entitled "Employer Rights and Responsibilities Following an OSHA Inspection," which has additional details on the types of violations and associated penalties, may assist you in understanding our penalty structure associated with different types of violations for which citations are issued.

Forklift Regulation 1910.178 "in need of repair," "defective," and "unsafe."

Issue: The language of 29 CFR 1910.178(p)(1), requiring that "[i]f at any time a powered industrial truck is found to be in need of repair, defective, or in any way unsafe, the truck shall be taken out of service until it has been restored to safe operating condition," and 1910.178(q)(1), requiring that "[a]ny power-operated industrial truck not in safe operating condition shall be removed from service" are seemingly inconsistent.

Question 1: Can OSHA provide specific definitions of "in need of repair" and "defective?"

Reply: It is first necessary to note that 1910.178(p) addresses the operation of a powered industrial truck, while 1910.178(q) addresses maintenance of industrial trucks, accounting for the difference in language between the two standards. While the former focuses on conditions under which a vehicle cannot be safely operated, the latter addresses when maintenance should be performed and by whom ("authorized personnel").

Neither 29 CFR 1910.178, its source standard ANSI B56.1-1969, nor the current ASME B56.1-2000 defines any of the words for which you request clarification. However, in determining whether a truck is " . . . in need of repair, defective, or in any way unsafe," OSHA would take a variety of factors into consideration. These factors include, but are not limited to, the condition of the truck itself, the manufacturer's limitations on the truck, and other safety issues, such as those considerations found in consensus standards like ANSI B56.1. While specific definitions of these words are not available, in this context OSHA will consider the totality of the circumstances surrounding a powered industrial truck in determining whether it is "in need of repair" or "defective."

Question 2: What does OSHA mean when the word "unsafe" is used in the standard, and can OSHA provide examples of an unsafe condition on a powered industrial truck?

Reply: "Unsafe," as used in 1910.178(p)(1), carries the general connotation of presenting a harm or risk. As stated above, OSHA will consider a number of factors in determining whether a powered industrial truck is unsafe. For example, all gauges must be functioning properly for the truck to be considered safe. Should a gauge not be functioning properly, that truck will usually be considered defective and in need of repair, thereby making the truck unsafe. Broken welds, missing bolts, or damage to the overhead guard would indicate that a truck is unsafe. Tires that are missing large pieces of rubber would present a risk to the truck operator, thereby making the truck unsafe. Such conditions must be repaired and corrected before the truck is placed back in service. It must be noted, however, that these are simply examples of unsafe conditions on a powered industrial truck; this list is not inclusive and there are certainly other conditions that would render a truck unsafe.

Forklift Operator Safety Training (29 CFR 1910.178 Compliance)