The central paragraph of the standard is 29 CFR 1910.178(l). It tells the employer what operator training must contain, who may give it and when it must be repeated. This lesson explains it so that you know what to expect from your employer.
Three parts of training
Paragraph (l)(2)(ii) says training consists of a combination of:
- Formal instruction: lectures, discussion, videos, written material. This course is a form of formal instruction on the general rules.
- Practical training: demonstrations by the trainer and exercises by the trainee on the truck.
- Evaluation of the operator's performance in the workplace: the trainer watches the operator work and decides whether the operator is competent.
All three are required. Formal instruction alone is never enough.
Who may train and evaluate
Only persons who have the knowledge, training and experience to train operators and to evaluate their competence may do so ((l)(2)(iii)). The standard does not name a profession or a certificate for the trainer. The employer must make sure the trainer really has these qualities.
Trainees
A trainee may operate a truck only:
- under the direct supervision of the qualified trainer, and
- where the operation does not endanger the trainee or other employees.
A trainee practices in a quiet area, not among a crowd of workers.
What the training must cover
The standard lists the topics in (l)(3). Two groups matter.
Truck-related topics, for example:
- operating instructions, warnings and precautions for the types of truck the operator will use;
- differences between the truck and an automobile;
- controls and instrumentation, steering and maneuvering;
- visibility, including restrictions caused by the load;
- fork and attachment use, capacity and stability;
- the inspection and maintenance the operator must do;
- refueling and charging or recharging batteries.
Workplace-related topics, for example:
- surface conditions where the truck will be used;
- load composition and stability, stacking and unstacking;
- pedestrian traffic in areas where the truck will be used;
- narrow aisles and other restricted places;
- ramps and sloped surfaces;
- hazardous locations, and closed or poorly ventilated areas where carbon monoxide or diesel exhaust can build up.
Training also covers the requirements of the standard itself.
When training must be repeated
Under (l)(4)(ii), refresher training is needed when:
- the operator has been observed operating the truck in an unsafe manner;
- the operator has been involved in an accident or a near-miss;
- an evaluation shows the operator is not operating safely;
- the operator is assigned a different type of truck;
- a condition in the workplace changes in a way that could affect safe operation.
On top of that, paragraph (l)(4)(iii) says an evaluation of each operator's performance must be done at least once every three years. The three years is the longest the evaluation may wait. Any of the events above brings refresher training earlier.
Training already received
Under (l)(5), if an operator has already received training in a topic, the employer does not have to repeat it, but only if that training is appropriate for the truck and workplace and the operator was evaluated and found competent.
The employer's record
Paragraph (l)(6) requires the employer to certify that each operator has been trained and evaluated. The record includes the operator's name, the date of the training, the date of the evaluation and the name of the person or persons who did the training or evaluation. In the standard, certification is the employer's record. It has nothing to do with the certificate of completion issued by this site.
Timing
An employer must train and evaluate a new operator before the operator is assigned to a truck ((l)(7)).
Key points
- Training means formal instruction, practical training and an evaluation at work.
- The evaluation is repeated at least every three years.
- Near-misses, a new truck type or a changed workplace bring refresher training.
- The employer keeps the record. No online course replaces any of it.