ABSTRACT

This paper explains the requirements of new OSHA regulations (1910.178 (l)) on powered industrial truck training. The paper explains who this regulation applies to and what employers must do to comply.

INTRODUCTION

The Occupational Safety and Health Administration (OSHA) of the US Department of Labor released new regulations December 1, 1998 requiring companies using powered industrial trucks to provide their operators with classroom and hands-on training by a trained, knowledgeable, and experienced instructor (29 CFR 1910.178 (L)). These new regulations are effective March 1, 1999, from which time employers must be actively working towards full compliance by December 1, 1999. State regulatory authorities must also respond to this new regulation in the next six months, ensuring that their local standards comply with the Federal Regulations at minimum. (Note however that many State Regulations surpass the federal guidelines).

WHO AND WHAT DOES THIS APPLY TO? (scope)

This new rule applies to all industries (general industry (1910), construction (1926), shipyards (1915), marine terminals (1917), and longshoring operations (1918)), with the exception of agricultural operations. This means employers from the small corner store to the international warehousing and/or manufacturing plant that use any kind of "mobile, power-driven vehicle … to carry, push, pull, lift, stack or tier [product or] materials" must provide their operators with adequate training.

The new regulations apply to any equipment covered by the specific industry standard. Under the General Industry Standard 1910, for example, these, but are not limited to, the following powered industrial trucks (regardless of their name):

  • fork trucks

  • tractors (tow, yard, etc.)

  • platform lift trucks (order pickers)

  • motorized hand trucks (powered pallet jacks)

  • and other specialized industrial trucks powered by electric motors or internal combustion engine.

Other industry standards cover such powered industrial trucks as:

  • industrial crane trucks

  • combination vacuum lifts

  • guided industrial vehicles

  • container top handlers

  • container reach stackers

  • semi-tractors/utility vehicles

  • straddle carriers

  • hustlers

  • top loaders

  • side handlers

NOTE: Earth moving and over-the-road haulage vehicles are excluded. Even earth moving equipment modified to accept forks.

WHO MUST BE TRAINED? (paragraph 1-i & 2-i)

Each and every operator. This means that full-time, part-time, seasonal, substitute, and occasional operators -- regardless of experience -- must be trained. In other words, you cannot legally allow any one of your operators - - even experienced operators -- to operate a powered industrial truck until they have successfully passed the required training and evaluation by a qualified instructor. OSHA feels that experienced operators who have learned through trial-and-error and have not had the benefit of safety training likely do not employ consistent safe driving habits and must therefore be trained.

The only exception to this requirement is during the training process itself, under supervision of a qualified trainer, and when the operation does not endanger any person.

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