If you employ new operators or temporary labor operators who claim prior training, you must evaluate the applicability and adequacy of prior training to determine if all required training topics have been covered. Factors to consider include the following:
- Type of equipment operated,
- Amount of experience on that equipment,
- How recent was this experience, and
- Type of environment in which the operator worked.
You may, but are not required to, use written documentation of the earlier training to determine whether an operator has been properly trained.
You or someone with the requisite knowledge, skills, and experience to perform evaluations may also simply evaluate the operator’s competency. You can determine from this information whether the experience is recent and thorough enough, and whether the operator has demonstrated sufficient competence in operating in the PIT to forego any or some of the initial training. Some training onsite regarding specific factors of the new operator’s workplace is likely to be necessary.
Under the OSHA multi-employer worksite policy, citations may be issued to employers that use temporary employees as forklift operators. If you supervise temporary employees, you would have the responsibility to ensure safe PIT operations. If the temporary employee claims prior training, you must, at the least, conduct a performance and knowledge evaluation, just as if he or she were one of your own new employee. Whether or not actual training will need to be conducted, depends on the results of the evaluation, prior training, etc. A temporary employee involved in an instance of unsafe operation, an accident, or a near-miss incident at your facility would also require refresher training before being allowed to resume driving a forklift vehicle