Is third-party forklift operator training actually OSHA-compliant?
𝐐: Is forklift operator training considered OSHA-compliant if it's conducted by a third-party trainer, such as a forklift rental company, safety consultant, etc.?
𝐀: The short answer is...probably not...but it depends.
Forklifts fall under OSHA's Powered Industrial Truck (PIT) standard (1910.178) and Material Handling Equipment standard (1926.602). Regardless of which standard applies, they both follow the training requirements in 1910.178. However, there's one key compliance factor, which is the workplace-related topics mentioned in 1910.178(l)(3)(ii), such as:
• Surface conditions where the PIT will be operated;
• Type of load(s) that will be handled by the PIT Operator;
• Pedestrian traffic in areas where the PIT will be operated;
• Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust; and
• Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation of the PIT
Understanding these topics will be specific to YOUR worksite, then unless the third-party trainer is covering the workplace-related topics of YOUR workplace, then the third-party training, by itself, would NOT be OSHA-compliant and could result in an OSHA citation.
When attending off-site trainings (e.g., at a forklift rental company's facility), they're usually an open-enrollment format w/ people attending from multiple companies. Even though these trainings usually cover the PIT-related topics (e.g., steering, lift capacity, stability, etc.), this format usually requires the training to be vague and not OSHA-compliant due to not covering YOUR specific workplace-related topics.
𝐂𝐚𝐧 𝐈 𝐛𝐫𝐢𝐧𝐠 𝐭𝐡𝐢𝐫𝐝-𝐩𝐚𝐫𝐭𝐲 𝐭𝐫𝐚𝐢𝐧𝐞𝐫𝐬 𝐭𝐨 𝐨𝐮𝐫 𝐟𝐚𝐜𝐢𝐥𝐢𝐭𝐲 𝐭𝐨 𝐜𝐨𝐧𝐝𝐮𝐜𝐭 𝐭𝐡𝐞 𝐭𝐫𝐚𝐢𝐧𝐢𝐧𝐠?
Sure! However, they still have to cover workplace-related topics. While bringing third-party trainers to your facility allows them to focus specifically on your employees, employers still must ensure all of the workplace-related topics are being covered.
𝐈𝐬 𝐇𝐚𝐧𝐝𝐬-𝐎𝐧 𝐓𝐫𝐚𝐢𝐧𝐢𝐧𝐠 𝐑𝐞𝐪𝐮𝐢𝐫𝐞𝐝?
Yep! Per 1910.178(l)(2)(ii), training must consist of a combination of formal instruction, practical training, AND evaluation of the operator's performance in the workplace. This means that the training must include you operating a PIT in YOUR workplace - not off-site in a training center's parking lot.
𝐒𝐨, 𝐰𝐡𝐚𝐭'𝐬 𝐲𝐨𝐮𝐫 𝐨𝐩𝐭𝐢𝐨𝐧𝐬?
In general, there's 2 options:
• Conduct in-house training/evaluation at your worksite by a qualified trainer/evaluator (either in-house or third-party) in accordance w/ 1910.178(l)(3); or
• Have a qualified third-party trainer conduct training covering the PIT-related topics mentioned in 1910.178(l)(3)(i), then supplement it w/ training/evaluation conducted by a qualified in-house trainer/evaluator that covers your workplace-related topics specified in 1910.178(l)(3)(ii).
Comments (4)
Great post Drew! I'm a huge proponent of site-specific training & getting guys to do tasks for PIT evaluation that is similar to what they will do for their work.
You are, as always 1000% RIGHT ON Drew!
As a third-party I have trained "Train-the-Trainer" skills of PIT operation at WI Technical Schools, but make it very clear that this does not mean anyone is approved to operate any PIT for a specific company on their site. Only the employer may do that. We go over 1910.178 similar to the way you have above.
Just as you have, I as a third-party agent (or "contractor") have went on a customer's plant floor and familiarized myself with the plant environment and their equipment. Once that has been done I if I feel the employer's training program is adequate will use their program, or I will develop one for them, I may approve operators to operate PITS after I have trained and EVALUATED their competency as satisfactory. I am acting as an agent of that company.
Thank you for things to consider, I have used third parties quite a bit and never considered it might be an OSHA violation. I'll be rounding up the clients for meetings soon. I'll be sure to keep this in mind.