Safety Knights

Having a conversation with them would not constitute training/re-training. Training in accordance with 1910.178 has to consist of 3 things: formal instruction (e.g., classroom lecture, video, etc.), practical demonstrations and exercises, and a performance evaluation of the person operating the PIT. Per 1910.178(I)(4)(i), it states the following, which states that you have to do training AND an evaluation of the effectiveness of that training (could be written exam, but highly preferred to do an actual performance evaluation):

"Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely."

It goes on to say that "refresher training in relevant topics shall be provided to the operator when...". With that being said, you have two options: (1) you can do a formalized training over just the issues that need to be addressed (e.g., proper cornering, traveling at the right speed, how to go up and down ramps, etc.), or (2) you can send them through the entire course again (recommended as a CYA and best practice).

As far as documentation, you would need to either have a written exam and/or a documented performance evaluation (recommended) that covers the applicable topics. The training roster/sign-in sheet would need to state that it's refresher training. If you go through the entire training again, you can put that the standard covered was 1910.178. However, if you just did refresher training on a specific topic (e.g., steering and maneuvering), you can put that specific portion of the standard (1910.178(I)(3)(i)(E)).

Normally we would have the redo the training as well as a conversation and accident review. Just make sure you document everything and you’ll have it covered