Would a written exam alone (i.e., without practical operation of the truck) suffice for the required 3-year operator evaluation?

The “evaluation” of “performance” required by the OSHA standard cannot be met by a written exam alone. A written exam by itself does not indicate whether the operator is operating the powered industrial truck safely. In most cases, the person conducting the evaluation would do two things: first, observe the powered industrial truck operator during normal operations to determine if the operator is performing safely, and second, ask pertinent questions to ensure that the operator has the knowledge or experience needed to operate a truck safely. In some cases, because of the danger or complexity of the operation, the extent of the change in conditions, or the operator’s need for additional skills, the evaluation will need to be lengthier and more detailed.