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Compliance considerations

Backup generators help keep businesses running, but they also impact the environment. Companies must follow air quality regulations to reduce pollution and operate safely.

Air permits

•State agencies usually oversee air permits, but The U.S. Environmental Protection Agency (EPA) has granted many county and city agencies the authority to issue them. For major permits such as New Source Review (NSR) and Title V, federal regulations apply, but state or local governments may still manage the process.

•In some areas, businesses can apply for a general permit or permit-by-rule for emergency generators. These permits are often easier to obtain and take less time to process. Checking air permitting regulations will help determine if this option is available.

•Businesses should find out if they need a pre-construction or construction air permit before setting up an emergency generator. These permits are based on the proposed equipment’s potential to emit (PTE) of criteria pollutants such as NOx, SO2, CO, and CO2 and hazardous air pollutants (HAPs) such as formaldehyde and acrolein, which are emitted during the combustion of fuel. The type(s) of fuel used in the generator, such as diesel, natural gas, gasoline, or propane, will affect the calculated PTE. Read more about construction permits in this ezExplanation: NSR Permits.

(Note: many state and local permitting agencies allow for the use of 500 hours for calculating PTE from an emergency engine, as per EPA’s 2011 Fox Memo, but some agencies still require using 8,760 hours and only accept 500 hours as an enforceable limit defined in a permit.)

•Federal law sets a limit on emergency generators, allowing less than 100 hours of non-emergency use per year. This includes maintenance and testing. Some permits may also restrict the times of day when the generator can be used for non-emergency purposes.

•The permit may require businesses to use the generator according to the manufacturer’s specifications. This is especially important if the business used manufacturer guarantees to calculate PTE.

•Businesses must track fuel use and operating hours to stay within the limits used in emissions calculations. They can do this using fuel records, fuel measuring devices, and hour meters that log the generator’s usage time.

•After getting a construction permit, a facility may need to apply for an operating permit within a year of the generator beginning operation. Some state and local agencies have stricter rules and deadlines. Check out J. J. Keller’s ezExplanation for Operating Permits: Clean Air Act: Operating Permits

EPA emission standards

The EPA enforces strict emissions regulations for stationary engines. Businesses must ensure their generators meet the New Source Performance Standards (NSPS) for compression ignition (40 CFR 60 Subpart IIII) and spark ignition internal combustion engines (ICE) (40 CFR 60 Subpart JJJJ), which can be found here. Additionally, the National Emission Standards for Hazardous Air Pollutants (NESHAP) apply to reciprocating internal combustion engines (RICE). 40 CFR 63 Subpart ZZZZ can be found here.

These rules, depending on the specific type of generator engine, will be required even if a permit is not necessary.

Other Regulations

Keep in mind that using an emergency generator may also involve other factors depending on the type and amount of fuel stored:

•Aboveground Storage Tank (AST) Requirements

•Spill Prevention Control and Countermeasure (SPCC) Plans

•EPCRA Tier II Reporting

Key to remember: When installing an emergency generator, companies must navigate complex air quality regulations to ensure compliance. By selecting the right fuel type and securing necessary permits, businesses can maintain reliable power while minimizing environmental impact.

Proposed legislation

Bipartisan legislation has recently been introduced in the House that would require businesses to provide restroom access to truckers who are loading or delivering cargo at their warehouses, manufacturers, distribution centers, retailers, and ports.

Supported by leading organizations in the trucking industry, the Trucker Bathroom Access Act (H.R. 9592) was introduced on Dec. 15, 2022. The bill requires retailers, warehouses, and other establishments with existing restrooms to provide access to drivers who are loading or delivering cargo. Additionally, operators of ports and marine terminals must provide access for drayage and parking while accessing such restrooms.

This amendment to Title 49 would exempt some employers from the bill including filling and service stations, and restaurants 800-square feet or smaller with restrooms intended for employee use only. The bill doesn’t require employers to construct new restrooms but to give truck drivers the same access as employees or customers.

Your restroom availability affects their health

Commercial truckers and delivery drivers are the lifeline of our supply chain of supplies, products, and consumables. Working tirelessly all hours, during holidays and weekends, and throughout the pandemic, they continue to deliver critical food and emergency supplies to companies everywhere. Employers have the privilege of demonstrating gratitude to truckers and delivery drivers with a positive work environment.

The benefits of allowing truckers and delivery drivers the convenience and safety of readily available, sanitary restroom facilities are plenty. They’re able to rest and reset when necessary, which keeps them and others safer on the roads. Equally important, restroom availability prevents drivers from having to search for available facilities elsewhere, allowing them to keep a timely delivery schedule, limit supply chain delays, and ultimately lower costs for employers and customers.

Keys to remember

The proposed Trucker Bathroom Access Act will require retailers, warehouses, and other establishments with existing restrooms to provide access to truckers and delivery drivers who are loading or delivering cargo. Access to restrooms keeps them refreshed and ready to deliver essential supplies to companies across the country.

The importance of CPR and early defibrillation

For every minute a patient is in cardiac arrest, their chances of survival decrease dramatically. When a patient doesn’t have a pulse and isn’t breathing, CPR should be performed until an AED is available. It’s important to note that CPR alone does not restart the heart. CPR is an oxygen circulation procedure. AEDs, on the other hand, are meant for lifesaving intervention.

CPR and early defibrillation are vital components of the emergency medical services (EMS) chain of survival that increases the odds of cardiac patient survival. However, according to the American Heart Association (AHA), even the best CPR can’t provide enough circulation of oxygen to the brain and heart for more than a few minutes. In fact, a patient whose brain is deprived of oxygen for 10 minutes or more seldom recovers.

Signs and symptoms of cardiac compromise

Just like a reliable vehicle, the circulatory system is the human body’s blood transportation system, and the heart is the engine. Amazingly, the heart generates its own electrical impulses, pumping in a regular, rhythmic manner. As with any engine, the heart requires a certain amount of pressure to function and doesn’t work well when clogged with grease or debris. The most common causes of sudden cardiac arrest include a heart attack, electrocution, and asphyxiation — all of which could occur in the workplace. Common signs and symptoms include:

• Chest pain accompanied by a crushing or squeezing sensation,
• Pain that radiates to the jaw or arm,
• Irregular pulse and/or abnormal blood pressure,
• Shortness of breath,
• Cool and sweaty skin,
• Nausea and vomiting, and
• Anxiety or feeling of impending doom.

CPR provides the pressure for the body’s “engine” to oxygen circulating, while an AED provides the electrical impulses to keep the engine pumping.

OSHA requirements regarding CPR

OSHA 1910.151 requires first aid treatment be provided in the absence of an infirmary, clinic, or hospital in near proximity to the workplace used to treat injured employees. This may include assisting a victim of cardiac arrest using CPR or defibrillation.

OSHA requirements for CPR and defibrillation differ considerably. Standards requiring CPR include:

• 1910.146 Permit-required Confined Spaces
• 1910.266 Appendix B: Logging Operations – First Aid and CPR Training
• 1910.269 Electric Power Generation, Transmission, and Distribution
• 1910.410 Qualifications of Dive Team and
• 1926.950 Construction Subpart V, Power Transmission and Distribution

OSHA recommends basic adult CPR refresher training and retesting every year, and first aid training at least once every three years. CPR training include facilitated discussion along with ’hands-on’ skills training that uses mannequins and partner practice.

OSHA requirements regarding AEDs — you might need a prescription

Though OSHA recognizes AEDs as important lifesaving technology that plays a role in treating cardiac arrest, the agency doesn’t currently require their use in the workplace. Instead, OSHA wants employers to assess their own requirements for AEDs as part of their first aid response.

AEDs are considered Class III medical devices which means the Food and Drug Administration (FDA) has some oversight on their use. Almost all AEDs require the purchaser to obtain a prescription from a physician under FDA regulations. The prescription process is meant as a quality control mechanism to ensure AEDs are properly maintained, that all designated responders are properly trained, and assist employers with establishing an emergency response plan for their workplace AED program.

The AHA requires AED operators to also receive CPR training as an “integral part of providing lifesaving aid to people suffering sudden cardiac arrest.” Though easy to use, each AED is slightly different, so training helps users understand the unique traits and supplies for the individual units at their workplace. Additionally, AED users must be trained to understand the signs of a sudden cardiac arrest, when to activate the EMS system, and how to perform CPR.

AEDs are light, portable, easy to use, and inexpensive. They’re best placed near high-hazard areas such as confined spaces, near electrical energy, or in remote work areas. Response time to reach AEDs should be kept within 3–5-minutes.

Training requirements

Many states require or encourage CPR and AED training from nationally recognized organizations. Any AED training should include CPR training. OSHA doesn’t offer first aid or CPR training, nor certify trainers. Training by a nationally recognized organization, such as AHA, the American Red Cross, or National Safety Council is recommended.

Keys to Remember

While OSHA doesn’t currently require the use of AEDs in the workplace, they do expect employers to assess their own AED requirements as part of their first aid response. AED training is required by most states and should include CPR with a hands-on practical component.

Hazardous materials

The term hazardous material is defined by the Department of Transportation. It refers to any substance or material that poses an unreasonable risk to health, safety, and property during transportation. Hazardous materials include hazardous substances, hazardous wastes, marine pollutants, and elevated-temperature materials. Essentially, if it’s dangerous and transported, it’s considered a hazardous material.

Hazardous waste

On the other hand, hazardous waste is defined by the Environmental Protection Agency. It refers to contaminated chemicals or by-products that no longer serve their purpose and need to be disposed of. Hazardous wastes are either listed or exhibit characteristics like ignitability, corrosivity, toxicity, or reactivity. It’s essentially waste that poses a danger to health or the environment and requires special handling and disposal.

To put it simply, hazardous material is a broad term that includes various dangerous substances during transportation, while hazardous waste specifically refers to dangerous by-products that need disposal. Understanding these terms is crucial for compliance with environmental and safety regulations.

If you ever find yourself unsure, remember that hazardous materials are about transportation risks, and hazardous wastes are about disposal risks.

6 frequently asked questions

1. What should CDL/CLP drivers and employers do to get ready for these changes?

• Monitor the SDLA: Drivers and employers should check their SDLA’s transition date and procedures. All SDLAs must switch to the new system on or before June 22nd.

The FMCSA link below displays the states that have transitioned so far:

National Registry

• Follow the current process until transition: CDL/CLP drivers must keep submitting copies of each medical certificate until their SDLA tells them to stop.
• Prepare for the transition: Update internal processes and train staff in the new procedures. If more than one licensing state is involved, there may be more than one process to update driver qualification (DQ) files until all SDLAs transition.

2. What should be done after the transition date or by June 23,2025?

• Carriers: Must place motor vehicle records (MVRs) in the driver qualification (DQ) file within the required timeframe (to be determined). They no longer need to note that the certified medical examiner (CME) was on the Registry.
• CDL/CLP drivers: Must continue to self-certify their driving tier (interstate or intrastate) and whether they need to be medically certified (Excepted/Non-excepted) when they apply for a new, renewed, or upgraded CDL/CLP.
• Carriers and/or drivers: Schedule exams well before the expiration date. Enforcement must go by what is in the CDL Information System (CDLIS). If a CDL driver does not have the medical card that was just issued, the system may show their certification as expired if there is any delay in transmission and the old expiration date has passed.

3. Will clinics automatically issue medical cards to CDL/CLP drivers? What if they don’t?

On and after June 23,2025, examiners don’t have to issue CDL/CLP drivers’ medical cards unless they ask for one. It is not known if every clinic will issue medical certificates.

There is a potential 2 to 4-day gap for the information to show on the MVR.

• Examiners must enter the exam results by midnight of the day after the exam.
• The data transfer from the registry to the SDLA takes about two days.

Given the potential gap in proof of medical certification, two best practices to consider:

1. To minimize roadside inspection concerns, carriers should direct CDL/CLP drivers to ask for a medical card to carry until the new medical certification information is on their MVR.
2. The driver should give a medical certificate copy to the carrier to show they have passed the exam.

4. How long will carriers have to place an updated MVR in the DQ file?

Currently, carriers have 15 days after each exam to place a CDL MVR in the DQ file. On and after June 23rd, this time may be shorter if FMCSA changes the rule. By June 23, 2025, the MVR should reflect the current information in 2-4 days after the exam.

5. Why are procedures changing?

FMCSA published a rulemaking in 2015 that requires SDLAs to connect to NRCME, but the initiative was delayed more than once. The connection simplifies the CDL medical certification documentation process and accounts for every medical examination, even disqualifications.

6. Does this rule impact non-CDL drivers?

No. Drivers who hold non-CDL licenses will still receive a medical certificate which should not be submitted to their SDLA.

Key to remember: Carriers and drivers must understand their responsibilities in this critical transition to avoid CDL driver medical qualification issues.

Two-part assessment

The policy advises officers to begin all roadside inspections in English. If it seems the driver may not understand the officer’s initial instructions, the officer is directed to conduct a two-part assessment to evaluate the driver’s compliance with the English language standard.

The first step is a driver interview, though details of the interview process were redacted from the public version of the policy. The policy says drivers should not use tools to facilitate communication during the interview, such as interpreters or smart-phone applications.

The policy directs officers to cite drivers for a violation if they cannot pass the interview portion of the assessment.

Step two in the assessment is evaluating whether the driver can recognize common highway traffic signs. The policy contains images of signs officers can use for this part of the test, but those too are redacted from the public version of the policy.

‘Out of service’ as of June 25

If a driver fails the test, the policy says the officer should:

1. Cite the driver for a violation of 391.11(b)(2);
2. Document evidence to support the violation, including the driver’s responses or lack thereof;
3. Beginning June 25, place the driver out of service (June 25 is when the violation will be added to the North American Standard Out-of-Service Criteria, as previously announced by the Commercial Vehicle Safety Alliance); and
4. When warranted, initiate an action to disqualify the driver from operating commercial motor vehicles in interstate commerce.

Drivers who are placed out of service won’t be allowed to drive until they can meet the English language requirements.

The policy applies to all federal enforcement personnel who perform inspections on drivers engaged in interstate commerce. Its effect on state-level enforcement remains unclear for now.

According to the policy, drivers in a commercial zone along the U.S.-Mexico border may be cited but should not be placed out of service.

The regulation

The Federal Motor Carrier Safety Regulations state that commercial drivers must be able to “read and speak the English language sufficiently to converse with the general public, to understand highway traffic signs and signals in the English language, to respond to official inquiries, and to make entries on reports and records.”

The new policy replaces a 2016 policy that ordered inspectors not to place drivers out of service for violating the language requirement.

The basics of logging exemptions

To be able to use this logging exemption in 395.1(e)(1), the driver must:

• Stay within 150 air-miles of the work reporting location for the day (draw a 150 air-mile radius circle around the work reporting location for the day — the driver must stay within this circle),
• Be back to — and released from — the work reporting location for his/her 8- or 10-hour break within 14 hours, and
• Include the starting and ending times for the day and the total hours on duty on the time record for the day.

The company must retain the time record and have it available for inspection for six months.

What if the driver goes too far or works too many hours?

If the driver cannot meet the terms of the exemption (he or she goes too far or works too many hours), the driver must complete a regular driver’s log for the day as soon as the exemption no longer applies.

If the driver has had to complete a log 8 or fewer days out of the last 30 days, the driver can use a paper log for the day. If the driver had to complete a log more than 8 days out of the last 30 days, the driver needs to use an electronic log for the day (unless one of the ELD exemptions applies, such as operating a vehicle older than model year 2000).

30-minute break exemption

When a property-carrying driver is operating under the 150 air-mile exemption, the driver is also exempt from having to take the required 30-minute break (see 395.3(a)(3)(ii)).

If the driver began the day as a 150 air-mile driver and has driven more than 8 consecutive hours without a break, and something unexpected happens and the driver can no longer use the 150 air-mile exemption, the driver must stop and immediately take the 30-minute break as well as start logging. If the driver went outside of the 150 air-mile area before the driver had 8 hours of driving without a break from driving, the driver would be expected to take the break at the appropriate time.

Common myths

Here are some of the common myths and misunderstandings about the 150 air-mile exemption:

• The driver must have the time records in the vehicle. Myth. The driver simply needs to explain to an officer during a roadside inspection that he/she does not have logs due to operating under the 150 air-mile exemption and that the required time records are back at the carrier’s office (just telling the officer, “I don’t have any logs” will lead to a violation, so the driver needs to know to provide the full explanation).
• The driver must log the previous seven days if he/she had been using this exemption and suddenly can’t. Myth. If the driver cannot use the exemption on one particular day, that is the only day the driver must use a regular log (either paper or electronic).
• Passenger-carrying drivers and drivers hauling hazardous materials cannot use this exemption. Myth. There are no restrictions on the use of this exemption, so any commercial driver can use it.
• A driver that crosses state lines cannot use this exemption. Myth. As this exemption appears in the Federal Motor Carrier Administration (FMCSA) regulations, it can be used by interstate drivers.
• Only drivers that operate out of a “company terminal” can use the 150 air-mile exemption. Myth. As long as the driver makes it back to the work reporting location for the day within the appropriate number of hours, the driver can use the exemption.
• Drivers that move from one jobsite to another every few weeks cannot use this exemption. Myth. If a driver that normally uses this exemption switches work reporting locations, the day the driver switches work reporting locations is the only day the driver cannot use the exemption.
• Drivers covered by this exemption are also exempt from the driver qualification (licensing and medical cards), driving, and vehicle inspection requirements. Myth. The only rules the driver is exempt from are the logging requirement in 395.8 and the 30-minute break requirement in 395.3.
• The driver cannot drive more than 150 miles for the day. Myth. The driver can drive as many miles as he/she wants to or needs to, as long as the driver stays within the 150 air-mile radius circle and gets back to the work reporting location within the appropriate number of hours.
• If a 150 air-mile driver gets into a vehicle with an ELD, the driver must use it. Myth. The carrier can have the driver log in and have the driver entered into the system as an “exempt driver,” or the carrier can request that the driver not log into the device and then attach a comment to the unassigned driving time generated by the driver’s movements. The comment would need to explain that the driver using the vehicle was a 150 air-mile driver who submitted a time record. It is up to the carrier to decide which option to use. If stopped for a roadside inspection, the driver will need to be able to explain to the inspector that he/she is an exempt driver using the 150 air-mile exemption, so using the electronic log is not required.

What’s different with the ‘150 air-mile non-CDL property-carrying drivers’

The 150 air-mile exemption at 395.1(e)(2) only applies to drivers that: Operate property-carrying vehicles that do not require a CDL to operate, and Stay within the 150 air-miles of their work reporting location.

If the driver stays within the 150 air-mile radius of the work reporting location, and returns to the work reporting location within 14 hours on 5 of the last 7 days, and 16 hours on 2 of the last seven days, the driver is allowed to use a time record in place of a log.

If the driver does not meet the terms of the exception, the driver will need to complete a log for the day. If the driver had to log more than 8 days out of the last 30 days, the driver will need to use an electronic log for the day. All of the other issues discussed above would apply to these drivers as well.

Managing the use

If you have drivers that use these exemptions, you will need to check time records to make sure they are complying with the appropriate time limits. You will also need to check movement records to verify that the drivers using these exemptions are staying within the mandated area (within 150 air-miles of the work reporting location for the day).

If a driver is over the hours limit, or has gone too far, you need to verify that the submitted a log for the day, either paper or electronic, depending on how many days the driver had to log out of the previous 30 days.

Verifying compliance is important

During an audit, if it is discovered that your drivers are using these exemptions incorrectly, you will be cited for not having drivers’ logs when required. Each day this occurred will be another violation, so the fine could be rather large if you are not managing the use of these exemptions!

What is a split specimen?

When a driver gives a urine sample for the purposes of DOT drug testing, the collector will split the specimen into two separate containers. The container labeled as the primary specimen will be tested by the lab; the container labeled as the secondary specimen is only tested if the driver requests that it be tested after the primary specimen is verified as positive, adulterated, or substituted.

How does a driver request that the split specimen be tested?

When the medical review officer (MRO) contacts the driver about a verified positive, adulterated, or substituted test, the MRO will inform the driver of the driver’s right to have the split specimen tested. The driver then has 72 hours from the time of notification to request via the MRO that the split specimen be tested.

What happens while the split specimen is being tested?

Because the driver’s primary specimen was verified positive, adulterated, or substituted, the motor carrier should have already pulled the driver from performing safety-sensitive functions. The driver cannot resume driving while the split specimen is being tested. Whether the driver is reassigned to a non-driving position or is suspended depends on the motor carrier’s drug and alcohol policy.

Who pays for the split specimen to be tested?

The regulations specify that the carrier cannot delay lab testing in order to collect payment from the driver. The secondary specimen should be submitted for testing as soon as the driver requests it, and motor carrier will be billed through the carrier’s lab account. In some cases, the motor carrier can seek reimbursement from the driver for full or partial costs of the split-specimen test.

Is the drug violation reported to the Drug and Alcohol Clearinghouse right away, or does the MRO wait for the results of the test on the secondary sample?

The MRO will report the positive, adulterated, or substituted drug test result to the Drug and Alcohol Clearinghouse within two business days of verifying the result for the primary specimen. Once the MRO receives the lab results for the secondary sample, one of three things happens:

1. The secondary test result reconfirms the primary test result. The violation stands and remains in the Clearinghouse.
2. The test of the secondary sample fails to reconfirm any of the original findings. The test will be canceled, and the MRO will change the result in the Clearinghouse within one business day of receiving the secondary test results.
3. The test of the split specimen does not reconfirm the original result but identifies something suspicious in the secondary sample. The regulations in 40.187 spell out a variety of situations that require the driver to be tested again, such as if the secondary sample is invalid or if part of the original result is reconfirmed but the sample also tests as substituted or adulterated. If any of these complex scenarios applies, the MRO will direct the carrier’s designated employer representative (DER) to immediately send the driver for another collection under direct observation. If that test result is negative and is not adulterated or substituted, the MRO will change the result in the Clearinghouse within one business day of receiving the secondary test results. Otherwise, the violation will stand and remain in the Clearinghouse.

Key to remember: Dividing a urine specimen into two samples allows for a driver to request that the secondary sample be tested if the first specimen indicates drug use. This is an important part of the driver’s right to due process.

What is 392.2C?

Section 392.2C is enforcement’s code for “failure to obey traffic control device.” The C stands for control.

The citation appears in the severity table for the Unsafe Driving BASIC (Behavior Analysis and Safety Improvement Category). The violation has been assigned a value of 5 out 10, with 10 being the most severe. The violation is used when calculating both the carrier’s and driver’s Unsafe Driving BASIC scores.

In most instances, the traffic control device is not a signal light or stop or yield sign. Rather, it is the sign that instructs the driver to pull into a weigh station.

Who must pull into a weigh station?

The vehicles that must stop at scales and inspection locations vary from state to state and even from location to location within a state. The “weigh scale ahead” or similar sign should be the driver’s guide.

If the sign reads:

• All vehicles over 16,000 pounds, the driver can safely bypass the scale if under the weight threshold.
• All commercial motor vehicles, the driver should pull in. It is far better to be waived or green lighted through than to be chased down.

Often those who operate commercial vehicles not requiring a commercial driver’s license, such as a large pickup truck or small box truck, mistakenly believe weigh scale inspections are just for larger rigs.

What happens when a driver ignores signage?

If a driver goes past a weigh station without pulling in as directed by a traffic control device, enforcement will pursue and pull over the driver. The officer will then escort the driver back to the weigh station for a roadside inspection.

Even if the driver was honestly confused whether the sign applied to the vehicle, it is too late. And more than likely enforcement’s interest has been piqued. It is highly unlikely the driver will be waived through at this point, and 392.2C will be entered on the roadside inspection report.

Handling violations

CSA’s enforcement model suggests finding the root cause of roadside inspection violations to prevent future occurrences and ultimately improve BASIC scores.

A violation of 392.2C may have one of several root causes, such as:

• Confusion over applicability
• Inattentiveness (missing the sign)
• Running late
• Risky behavior (taking the chance that no one will pursue)
• Concern over other violations discovered once stopped

Whatever the reason, it must be addressed with the driver. Corrective actions range from refresher training to termination. If the driver was trying to avoid enforcement for other reasons (drugs, alcohol, over HOS limits), these other violations need to be addressed accordingly.

Key to remember: Failing to obey a traffic control device will be used in calculation of the CSA Unsafe Driving BASIC scores. Motor carriers should address the root cause of the violation so it does not recur.

The intent of the standard

OSHA’s powered industrial truck (PIT) standard (29 CFR 1910.178) is intended to ensure the safe use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. The standard outlines requirements for operational permits and certification.

And, though not specified in the standard itself, PIT operators must be at least 18 years old per federal child labor regulations.

License and certification Q&A

The OSHA PIT standard clearly defines requirements for training and certification. However, some licensing and certification information isn’t as clear. Here are some clarifications:

Q: Who can train, evaluate, and certify PIT operators?

A: OSHA requires in 1910.178(l)(2)(iii) that, “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.” The OSHA standard doesn’t further define this requirement or set any specific or additional certifications.

Q: Does OSHA require PIT operators to have a valid driver's license?

A: Federal OSHA has no requirement that a forklift operator has a valid motor vehicle driver's license. Some states are more stringent, so check your local and state requirements to confirm.

Q: Does OSHA have regulations that impact an employee’s ability to operate PITs if they’ve received a DUI or suspended license?

A: Because OSHA doesn't require a valid motor vehicle driver's license, the status of that license doesn’t impact PIT operator permitting. Individual states or the employer may have policies that dictate otherwise.

Q: Are PIT drivers required to have their license on them when they are working?

A: Federal OSHA doesn’t require PIT operators to have a license or permit. However, some states such as Michigan do require this. Typically, in states that require a permit or license, the license must be “readily available.” Companies have the option to require the permit or license be carried with the operator.

Q: Are operators required to be trained on each manufacture of PIT model?

A: A June 15, 1999, OSHA letter of interpretation (LOI) clarifies that operators are to be trained and evaluated in the safe operation for the type of truck they’ll be assigned. Operators wouldn’t need additional training for same truck types but would need additional training when truck- or workplace-related training topics are different.

Q: Do PIT operators need to be recertified if they move from one state to another with the same company?

A: In an LOI dated October 1, 1999, OSHA states, "As long as the employer has a reasonable basis to believe that the third-party trainer is qualified and has a program that meets the requirements of the standard, it can rely on that trainer to conduct the training and evaluation of employees and can certify that these employees have been trained. However, the employer may need to provide additional training on site-specific or truck-specific matters." This shouldn’t require retraining for the same type of forklift as already certified; however, workplace conditions or other factors of the new work location may require training for forklift operation in the other state(s).

Operator Impairments

In addition to being properly trained and evaluated, OSHA expects employers to ensure physical capabilities. OSHA references the American National Standards Institute (ANSI) Standard B56.1-1969. Section 6 clarifies that, “Operators of powered industrial trucks shall be physically qualified. An examination should be made on an annual basis and include such things as field of vision, hearing, depth perception, and reaction timing."

Employers should consider OSHA PIT regulations and the General Duty Clause, ANSI standards, and the Americans with Disabilities Act (ADA) requirements when evaluating physical qualifications. In short, if a worker demonstrates the visual, auditory, and mental ability to safely operate PITs, he or she is permitted to operate them.

Keys to Remember

OSHA requires employers ensure the safe use of forklifts and other powered industrial vehicles. Employers must ensure operators have the knowledge, skills, and physical ability to safely operate PITs.

The story

In 2023, to explore reasons for low morale, Christopher, a police officer, voluntarily conducted a wage survey of area law enforcement agencies. The survey showed that members of the city’s police department were paid less than those of other local law enforcement agencies. He presented the findings to Chief Kuth on October 31, 2023.

On November 17, Chief Kuth reassigned Christopher from his day-shift position as a detective to a night-shift position as a patrol officer.

On an unrelated note, on November 29, Christopher emailed his supervisor, with the HR director copied, to tell them that “in the next couple of months” he would need to receive treatment for a recurrence of cancer. In that email, Christopher recalled that when he went through a similar treatment several years earlier, he “didn’t miss much work then” and that he was “hoping for something similar” this time as well.

The HR director responded with FMLA paperwork attached, explaining, “I understand you don’t anticipate missing much work, but this is still an FMLA qualifying event.”

Chief Kuth fired Christopher 14 days later, on December 13.

Christopher sued, and the employer asked the court to dismiss the case.

The case and the findings

In court, the employer put forth two arguments:

• Christopher never provided proper notice of his need for FMLA benefits.
• It fired Christopher for legitimate reasons unrelated to his health issues.

Christopher had provided adequate notice of the need for leave. Chief Kuth argued that when he fired Christopher, he wasn’t aware of Christopher’s potential need for medical leave, so the leave had nothing to do with the termination.

Christopher’s supervisor, however, testified that he was “sure” that he told Chief Kuth that Christopher was planning to take medical leave, though he couldn’t recall when.

The employer also gave shifting explanations of why it fired Christopher.

Chief Kuth said that he fired Christopher for “insubordination” because Christopher “was saying that I was lying about not supporting [line officers] or helping them with wages.”

The police department, however, told the Arkansas Division on Law Enforcement Standards and Training that Christopher was “terminated for non-disciplinary reasons.”

Also, the employer policy required investigations into allegations of employee misconduct before taking disciplinary measures, and had investigative procedures that leaders had to follow.

But Chief Kuth never had any discussion with Christopher about the reason for his firing, and the chief never conducted any investigation into the allegations that Christopher called him a “liar” before firing him.

Therefore, the court did not dismiss the case as the employer had wanted. Instead, the court allowed it to proceed to a trial.

Collins v. City of Lowell, Arkansas, Western District of Arkansas, No. 5:24-CV-5122, May 1, 2025.

Key to remember: Employers may fire employees for legitimate reasons that don’t have to do with a request or taking of FMLA leave, but they need to be able to show what those reasons are. Otherwise, a termination can look like retaliation.

What is burnout?

Burnout is more than workplace stress, although stress can lead to burnout if it’s not addressed.

A person under stress may believe they will feel better once they catch up on tasks or make it through a challenging time.

A person who is burned out is overwhelmed, exhausted, cynical, and deeply disinterested in their work. They may not care whether they finish tasks, and if they do finish, it brings no relief.

As with stress, burnout can lead to headaches, irritability, and lack of focus. It can make it difficult to sleep, despite always feeling tired.

Burned out workers are more likely to miss work. They are less likely to discuss issues with their manager, and more likely to quit.

Which stressors are impacting workers today?

Attendee responses:

• Low rewards: 56.8 percent
• Conflicting expectations between customers and management: 49.5 percent
• Lack of control: 42.2 percent
• Long hours: 40.3 percent
• Job security: 24.8 percent
• Hostile work environment: 20.4 percent
• Relationships in the workplace: 18.9 percent

In addition to the items listed, attendees also mentioned these stressors:

• Lack of communication from leadership to employees
• Poor training
• Employees expected to pick up the slack for those who won’t or can’t do their job
• Decisions that are not supported by management
• Supervisors who constantly change their mind
• Family issues

How can you address workplace burnout?

There is no simple solution for alleviating all workplace stress. However, taking steps to determine some of the primary causes of stress in your workplace and creating a plan to act on them can help.

Input can be gathered through an employee survey or discussions with supervisors and managers. Steps can then be taken to help manage the primary causes of workplace stress and provide workers with tools to help them deal with the physical and emotional impact it brings.

This could include:

• Providing communication training to managers to help them provide support, recognition, and encouragement to their team.
• Looking at your policies to see where you can give workers more control. Options include flexible schedules and remote work opportunities to give workers more say in how the work gets done.
• Setting boundaries for technology by not expecting workers to answer emails after the workday ends.
• Highlighting career development opportunities to help employees improve their skills.
• Creating a peer-to-peer mentorship program for managers to provide them with a support network.
• Offering volunteer opportunities to provide social connections, emotional support, and work with a sense of purpose.
• Promoting the wellness resources your company offers. This could include an employee assistance program, financial planning assistance, and mental health benefits available through your health plan.

Key to remember: Workplace burnout is a growing concern, but employers can take steps to help workers manage the causes of stress that lead to burnout.

FMLA certification basics

Employers aren’t required to use certifications, but if they do, the U.S. Department of Labor (DOL) has five different certification forms to use for various FMLA leave situations.

The forms are as follows:

1. Certification of Health Care Provider for Employee's Serious Health Condition,
2. Certification of Health Care Provider for Family Member's Serious Health Condition,
3. Certification of Qualifying Exigency for Military Family Leave,
4. Certification for Serious Injury or Illness of a Current Servicemember for Military Family Leave, and
5. Certification for Serious Injury or Illness of a Veteran for Military Family Leave.

Let’s focus on the first two, as these are the most common ones HR administrators use.

Who can fill out an FMLA certification?

The FMLA regulations describe the person who has the authority to fill out a certification as a “health care provider.” The good news is, the regulations include a lengthy list of medical professionals who fit this role.

Under the FMLA, a health care provider includes:

• A doctor of medicine or osteopathy,
• A podiatrist,
• A dentist,
• A clinical psychologist,
• An optometrist,
• A chiropractor (limited to manual manipulation of the spine as demonstrated by X-ray),
• A nurse practitioner,
• A nurse midwife,
• A clinical social worker,
• A physician assistant,
• A Christian Science practitioner, and
• Any health care provider from whom the employer or the employer's group health plan's benefits manager will accept a medical certification to substantiate a claim for benefits.

To be qualified to fill out FMLA forms, medical professionals must be authorized to practice in the state and perform within the scope of their practice. This means that the provider must be authorized to diagnose and treat physical or mental health conditions.

What about doctors in a foreign country?

If an employee or an employee's family member is visiting another country, or a family member resides in another country, and a serious health condition develops, the employer must accept a medical certification from a health care provider who practices in that country. This includes second and third opinions.

If a medical certification from a foreign health care provider is not in English, the employee may be required to provide a written translation of the certification.

Key to remember: The FMLA regulations spell out which medical professionals can fill out certification forms.

#1 Start here

First, OSHA requires that all operators must be trained prior to being allowed to operate forklifts. And the same thing goes for pallet trucks, order pickers, and stand-up units…. Any powered type of material handling equipment requires training.

But what does training entail? Well, the OSHA regulations are very specific. All operators must receive a combination of training. Training must consist of formal training, which is a lecture, discussion, interactive computer learning, video tape, written material, and so on.

They must also receive practical training, which means demonstrations performed by the trainer and practical exercises performed by the trainee.

And the third component is that operators must receive a performance evaluation. So, they must operate the equipment and be observed and evaluated before being considered trained per the OSHA standard.

Usually, you’ll introduce the concepts during the classroom portion of training, the more informational aspects, such as the OSHA requirements. Then you’ll use the practical part of training to familiarize trainees with controls, talk about load handling, and so on. With the practical part, it’s usually best to ramp up the training, meaning start with simple skills and then build on those.

#2 Train on these topics

Aside from requirements for how to do the training, OSHA gives us a detailed list of topics to cover during the training.

The main categories are truck-related and workplace-related topics. And remember that OSHA does require you to include information on OSHA’s forklift standard as part of the training program. This requirement can be easy to overlook, but a good way to approach it is in the classroom portion of the program.

Keep in mind that if a topic doesn’t apply to your trucks or workplace, you don’t have to train on it. For example, if you don’t have any ramps or hazardous (classified) locations in your facility, your forklift operators don’t need training on these topics.

Truck-related topics include the following:

• Operation instruction, warnings
• Differences between forklift and automobile
• Controls, instrumentation
• Engine, motor operation
• Steering
• Visibility, restrictions
• Fork, attachment operation
• Capacity
• Stability
• Inspection, maintenance
• Refueling, recharging
• Operating limitations
• Operator’s manual instructions, precautions

Workplace-related topics are examples like these:

• Surfaces
• Load composition
• Load handling
• Pedestrians
• Narrow, restricted areas
• Hazardous (classified) locations
• Ramps
• Poor ventilation
• Other hazards

#3 Determine success

The trainees must successfully complete the formal and practical instruction, but how you determine success is up to you. For the classroom portion, you could give a written or oral test or otherwise evaluate the trainees’ knowledge. For the practical training, the trainee must be able to safely perform all the operations used on the job.

#4 End here

An evaluation of the operator’s performance in the workplace must be conducted at the time of initial training. And an evaluation is required to determine the effectiveness of any refresher training.

Also, you must conduct an evaluation at least every three years. This means that at least once every three years every operator must be observed while they operate in the workplace under actual workplace conditions. During the evaluation, the operator must also be able to answer pertinent questions to demonstrate they have the knowledge to operate the forklift safely.

A key point to note here, this evaluation must be more than just a written or verbal test. The employer must observe the operator in action performing all typical tasks related to running the forklift. And, going back to where we started, the evaluation must be conducted by someone who has the knowledge, training, and experience to evaluate the truck operator’s competence.

Document the evaluation — this means placing a record in your training file that includes the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation.

Action item

This may be a good time for you to review your options for training forklift operators to ensure they’re meeting these guidelines. And, it’s always a great idea to have all your training procedures in written format for consistency.

Key to remember

Training forklift operators is an OSHA requirement. Follow this step-by-step guide and you can do it in-house.

A late Senator Kennedy legacy

You could call the bill the “Kennedy Amendment.” The PAWA goes back to April 29, 2004. That’s when Senator Edward “Ted” Kennedy (D-MA) introduced it. Back then, the lawmaker acknowledged that it would be an “uphill battle” to get the bill through Congress. It’s unclear if he sensed it would take over 20 years, but he said he was committed to the fight. The Senator reintroduced or cosponsored the bill in 2005, 2007, and just days before he died in 2009.

When introducing the bill, Kennedy explained, “I’m committed to fighting for people like Jeff Walters, whose son Patrick was killed when a trench collapsed on him ... His employer was known to be violating critical safety rules. We will fight for people like Ron Hayes, whose son Patrick suffocated in a grain elevator … We intend to do everything we can to keep other working families from that grief.”

Kennedy argued, “These deaths and injuries aren’t accidents, they’re crimes, and it’s time we started treating them like crimes.” In fact, the Senator pressed, “Every year, over five thousand workers are killed and nearly five million others become ill or are injured on the job … Too many companies … blatantly ignore the law, but they never go to jail—even when their actions or lack of action kill loyal employees who work for them … Employers who violate safety laws again and again … treat [OSHA fines] as just another cost of doing business. We cannot let these shameful practices continue.”

Representative Courtney carries the torch

The PAWA has been bolstered and reintroduced with every Congressional session since Kennedy. House Representative Joe Courtney (D-CT) just floated the bill as H.R. 3036. The Congressmember shared: “Fifteen years ago, an explosion at an energy plant in Connecticut left six workers dead and dozens injured. Some of the workers who died were my friends, and I watched as their families fought for justice and accountability for years afterwards. Their story, and the horrifying reality that … workers die each day as a result of hazards faced at work, is why I am a champion for the Protecting America’s Workers Act.”

A fact sheet from Courtney claims that the Bureau of Labor Statistics estimates that 5,283 workers were killed on the job in 2023, and nearly 3.2 million workers suffered on-the-job injuries or illnesses.

What’s in the latest bill?

H.R. 3036, if passed, would:

It’s a safe bet that the PAWA will continue to be reshaped and reintroduced until signed into law.

Key to remember

The PAWA was reintroduced to expand coverage to public workers, increase penalties, and otherwise strengthen the OSH Act.

What regulations apply?

OSHA 29 CFR 1926.21 for construction operations, says: “In job site areas where harmful plants or animals are present, employees who may be exposed shall be instructed regarding the potential hazards, and how to avoid injury, and the first aid procedures to be used in the event of injury.”

Although there’s no similar general industry regulation for outdoor settings, workers should be trained on this recognized, serious hazard, too.

Insects

OSHA has no specific elements that must be covered when training on insect-related hazards. However, you may wish to share best practices when your crew is working in areas where ticks, spiders, bees, hornets, wasps, fire ants, and other insects may be present:

• Wear long pants, socks, and long-sleeved shirts, and tuck pants into boots or socks.
• Avoid wearing bright-colored clothing.
• Avoid swatting a flying insect. Instead, gently brush it aside or wait for it to go away.
• Use insect repellents according to product instructions.
• Avoid wearing sweet-smelling colognes and deodorants.
• Avoid eating in areas where insects are gathering.
• Check skin and clothing for ticks daily and remove ticks using fine-tipped tweezers.
• Remove a stinger by scraping it. Wash the affected area with soap and water or an antiseptic towelette. Do not scratch a sting.
• Treat bites/stings by evaluating the affected area and applying cold water or ice for pain. If not allergic, over-the-counter products may relieve pain and/or prevent infection.
• Seek prompt medical attention if new, severe, or persistent symptoms are experienced after a bite/sting. These may include swelling and pain at the bite/sting site, body/muscle aches, fever, headaches, fatigue, joint pain, rash, stiff neck, and/or paralysis.

Rodents and other animals

Bites and scratches from wild animals can cause injury and spread germs, even if the wound doesn’t seem deep or serious. Have your workers:

• Avoid contact with rodents or rodent-infested areas. If this isn’t possible, wear protective gloves and wash hands regularly.
• Avoid contact with wild or stray animals.
• Wash scratches or bites with warm soapy water immediately. Bandage the wound. Seek medical attention if the wound is serious; the animal looks sick or acts unusual; or if the wound becomes red, painful, warm, or swollen.

Plants

Plants like poison ivy, poison oak, and sumac have poisonous sap in their roots, stems, leaves, and fruit. If the stems or leaves are damaged, the sap may get on the skin through direct contact with the plant or by contaminated objects such as clothing, shoes, tools, and animals. Signs of an allergic reaction include itching, redness, a burning sensation, swelling, blisterings, and/or a rash.

To combat these plants on the job, share images of poisonous plants workers may be exposed to. Also, urge your workers to:

• Wear cloth or leather gloves, long-sleeved shirts, and long pants tucked into boots.
• Apply barrier cream/lotion to uncovered skin.
• Keep rubbing alcohol accessible to remove the oily resin up to 30 minutes after exposure.
• Wash an exposed area with cold running water if a worker has possible contact with a poisonous plant. Do not use soap since it may spread the oil.
• Wash contaminated clothing, handling it as little as possible until it’s soaked.
• If a rash develops, avoid scratching the area.

Snakes

Venomous snakes in the U.S. include rattlesnakes, coral snakes, cottonmouths/water moccasins, and copperheads. Workers should understand their exposure risk, how to prevent and protect themselves from snake bites, and what to do if they’re bitten. Share images of the types of snake(s) in your area, so workers understand how to spot a venomous snake. Safety tips include:

• Watching for snakes sunning themselves on fallen trees, limbs, or pathways.
• Wearing heavy gloves when removing debris and, if possible, not placing fingers under debris when moving it.
• Wearing leather boots at least 10 inches high.
• Stepping back and allowing a snake to move away. Snakes bite only when they feel threatened or trapped.
• If bitten, allowing the bite to bleed for 15 to 30 seconds. Clean and disinfect the area. Seek medical attention.

Key to remember: Outdoor workers exposed to plants and animals should be trained in hazard recognition, how to protect themselves, and what first aid measures to use. Construction workers must have that training when harmful plants or animals are present.

An example of half-truths

Let’s take our first aid program for example. When using a free AI tool, I asked it, “What are OSHA’s first aid program requirements?” and only got partial truths that could have resulted in compliance issues and potential citations.

AI advised that, “OSHA doesn’t have a specific “First Aid Program” standard, but their regulations do require employees to provide prompt medical attention under the General Duty Clause of the Occupational Safety and Health Act of 1970.”

Sure, this is partially true that the standard isn’t called a “First Aid Program” and there is a General Duty Clause. However, there is, in fact, an applicable Medical Services and First Aid standard at 29 CFR 1910.151 that this particular search didn’t identify.

Without putting in the proper manual (human) effort of verifying the information, I could have been led astray and missed a lot of key regulatory requirements that are necessary.

Putting in that extra bit of effort

AI can be incredibly helpful, but it’s not human. It can’t replace the experience and decision-making process we humans provide. The information or analytics put out is completely dependent not only on what information is initially put in (by humans), but also on how we develop the prompts telling AI what to look for.

For the above example, by changing my prompt from “what are OSHA’s first aid requirements” to “OSHA first aid standard,” I was finally provided information on 1910.151 that includes:

• "1910.151(a) - The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.
• 1910.151(b) - In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.
• 1910.151(c) - Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.”

When you see the word “shall” in any standard, the employer doesn’t have a choice — it must be done and if not, could be cited. So, without putting in the extra effort to do more AI searching and regulatory comparison, I may have missed these requirements, costing the company money in non-compliance, but more concerning, potentially causing serious injury to an employee.

Keep AI in check

To avoid First Aid and other program citations, we must keep AI in check by doing our homework to ensure the information is accurate. This can be done in various ways:

• Search using multiple AI tools and cross-reference the information;
• Compare information kicked out by AI with actual regulatory standards;
• Double check with the Federal Register to ensure the most up to date information is provided in the results; and
• Evaluate if information hasn’t been manipulated by potential hackers or other nefarious characters.

Keys to remember: AI output is only as good as the human-entered information it is searching and interpreting. Users must verify regulatory information to avoid potential citations for program non-compliance.

No driver’s license but must be 18 years old

Since forklifts are not operated on public roads, the operator does not need a driver’s license. In fact, OSHA requires training on the differences between a forklift and a car. Someone with a driver's license might assume that forklifts handle like cars, but they do not!

A forklift operator must, however, be at least 18 years old. That’s not in the OSHA regulations, but appears in the child labor regulations. Minors under 18 years of age cannot operate (or even ride on) equipment like forklifts or scissor lifts.

Seatbelts required

Everyone knows that forklift operators must use the seatbelt if the forklift has one. That does not appear in the OSHA standard, but it’s usually a safety warning in the forklift operator manual. Since failing to wear a seat belt is a recognized hazard that could cause serious injury, OSHA uses the General Duty Clause to cite employers that don’t enforce seatbelt use.

Hearing or vision impairments

Employers occasionally hire trainees with hearing loss, vision impairment, or other physical limitations. Alternatively, an experienced forklift operator could get injured or experience similar impairments. OSHA does not establish specific requirements for vision, hearing, or other qualifications, and physical limitations are not necessarily disqualifying.

Instead, employers must evaluate the individual and determine if the person can operate safely. Trainers should work with their Human Resources team to evaluate possible accommodations under the Americans with Disabilities Act. Do not assume that a physical limitation would prevent someone from becoming a safe forklift operator. If an evaluation finds that the person cannot meet acceptable safety standards, the employer may refuse to certify the operator.

Trainers might need training

The employer determines who is qualified to deliver powered industrial truck training. The trainer must have the “knowledge, training, and experience” to train and evaluate operators. Attending a “train the trainer” class and getting a certification isn’t a bad idea, but OSHA doesn’t require any particular course or certification to be a trainer.

OSHA does, however, require that the trainer have experience using the type of equipment that trainees will operate. Since experience is required, the trainer likely received training on using that equipment. Further, if the employer purchases a new type of truck or attachment that the trainer has never used, the trainer will need experience using that equipment before training others.

For related information, see our articles on Debunking the mysteries of forklift training (Part 1) and Debunking the mysteries of forklift training (Part 2).

Even minor modifications require approval

Modifications that affect “safe operation” require the manufacturer’s written approval per 1910.178(a)(4). In OSHA’s view, that covers nearly any change, even adding a warning light or backup alarm. A Letter of Interpretation dated April 11, 1997, clarified that if the manufacturer does not respond or refuses to approve a modification, employers may instead get approval from a Qualified Registered Professional Engineer. Employers should ensure that forklift operators don’t modify equipment, like adding plywood or tarps to the cage as a sun shade. Those changes could affect safe operation and would require approval.

Key to remember: The powered industrial truck standard does not address every issue that employers might face, but employers can find answers in other regulations or guidance.

Alternative glove selection for COVID-19

Here’s a summary of glove types and the protection given to help evaluate alternatives.

Butyl gloves protect against a variety of chemicals such as peroxide, highly corrosive acids, strong bases, alcohols, aldehydes, ketones, esters and nitrocompounds. Butyl gloves also resist oxidation, ozone corrosion and abrasion, and remain flexible at low temperatures. However, they do not perform well with aliphatic and aromatic hydrocarbons and halogenated solvents.

Natural (latex) rubber gloves have good elasticity and temperature resistance, and resist abrasions well. They protect against most water solutions of acids, alkalis, salts, and ketones. Latex gloves may cause allergic reactions and may not be appropriate for all employees. Hypoallergenic gloves, glove liners, and powderless gloves are possible alternatives for employees who are allergic.

Neoprene gloves protect against hydraulic fluids, gasoline, alcohols, organic acids, and alkalis. Their chemical and wear resistance are generally better than gloves of natural rubber.

Nitrile gloves are intended for jobs requiring dexterity, and they stand up even after prolonged exposure to substances that cause other gloves to deteriorate. They offer protection when working with greases, oils, acids, caustics, and alcohols but are not recommended for use with strong oxidizing agents, aromatic solvents, ketones, and acetates.