Are you qualified to conduct powered industrial operator training?
ONLY if you've "been there, done that". Allow me to explain. 👇🏻
OSHA's Powered Industrial Trucks standard (29 CFR 1910.178) states "All operator training and evaluation shall be conducted by persons who have the knowledge, training, AND experience to train powered industrial truck operators and evaluate their competence."
A 2003 OSHA standard interpretation reiterates this, and goes on to say that "the trainer will only have sufficient 'experience' if he has the practical skills and judgment to be able to himself operate the equipment safely under the conditions prevailing in the employer's workplace". The letter also states "For example, if the employer uses certain truck attachments and the trainer has never operated a truck with those attachments, the trainer would not have the experience necessary to train and evaluate others adequately on the safe use of those attachments. However, the standard does not require that the trainers operate a PIT regularly (i.e., outside of their operator training duties) as part of their job function or responsibility."
Check out the OSHA standard interpretation here: 👇🏻
https://www.osha.gov/laws-regs/standardinterpretations/2003-07-23
Comments (4)
Well I now do "Train-the-Trainer" PIT. One of the institutions I taught use to hold PIT Operator training and certify them as "operator's permits' using campus equipment. When they asked me to teach for them, I told them they could not certify or approve people to operate PITS at another place of business! I used the above and more info. They got very upset with me, said they had done it for years, and excused me. I thought that I would never hear from them again.
They called a couple days later asked me how I would design their instruction. I said, "#1 If you are going to "certify employees to drive at XYZ Company, they had to do it at XYZ Corporation on their equipment. #2 If they insisted to do training in their campus I could do "Train-the-Trainer"." So I got the job and have been sent out to a couple sites.
I have been in several OSHA audits and visits! I have never ever been asked about trainer qualifications by OSHA on anything, but I know they could especially if they were there due to a PIT accident. In my classes I say, "In my opinion when you are talking Trainer Qualifications the rubber meets the road when the company asks itself, 'Can we justify XX's qualifications and experience to be PIT trainer and defend it in a court or hearing?' If the answer is yes they are good, if no then you got to get other trainers!"
My qualifications as a Trainer - Trainer in PIT:
#1 Operated PITs off and on for >45 years
#2 Directly Supervised other PIT operators for >25 years.
#3 Managed Safety Programs >25 year including writing and administering PIT polices and procedures.
#4 Purchased several PITs.
#5 OSHA Outreach Instructor (GI). I know, I cannot "certify" people to drive in Outreach, just means I have read and studied 1910.178. I almost always talk about PITs for some time in Outreach, usually putting it in Material Handling module! Had to take OSHA 511, 510, and 503 (x3) to be "approved"
#6 I have a MS in Training (Adult Learning)