Thursday, December 22, 2011

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.

Thursday, December 8, 2011

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."