OSHA almost never issues citations under the regulation on forklift trainer qualifications, but training violations are among the most frequent citations. How can that be? Maybe OSHA finds citing the outcome easier than citing a trainer deficiency.
The forklift trainer requirements sound vague and circular. Paragraph 1910.178(l)(2)(iii) says that forklift operator training and evaluations must be conducted by someone who has the “knowledge, training, and experience” to train and evaluate operators. Basically, the training and evaluation must be done by someone who can effectively deliver the training and evaluations. So who is qualified to deliver the training?
Employer responsibility
The employer decides if a prospective trainer has the necessary knowledge, training, and experience to effectively deliver the training and evaluate performance. The trainer’s background might include attending certain courses, but OSHA does not require taking a specific course or obtaining a particular certification. The trainer must also know the regulations, the truck-related topics, and the workplace-related topics.
In addition, a trainer must have experience operating the types of trucks and attachments that trainees will use. A letter of interpretation dated July 23, 2003, noted that the “experience” requirement generally means the trainer has operated the same type of truck. If operators will use attachments, the trainer must have used that type of attachment.
Some employers use more than one trainer, such as one person for the classroom portion and another for the hands-on training and operator evaluation. That’s perfectly acceptable. For related information, see our article Want to provide forklift training in-house? No problem, here's how!
How many citations?
During fiscal year 2024, OSHA issued nearly 2,500 citations under the powered industrial truck standard, many of which relate to operator training. OSHA does not publish the specific paragraphs cited, but we have that data from several years ago. Of the thousands of 1910.178 citations, OSHA issued only one citation under the trainer qualification paragraph. Very likely, the trainer had never used the type of truck or attachment and therefore lacked the required experience.
As noted, however, OSHA frequently issues citations related to operator training. Those include failing to cover all required training topics, or simply an OSHA officer’s observation of unsafe operation, which suggests a training shortfall. Citations for inadequate training could mean that the trainer qualifications were lacking, or that operators simply did not remember their training. Either way, a violation (and therefore a safety hazard) has occurred.
Trainer evaluations
We get a lot of questions on the required qualifications for forklift trainers. As noted, the regulations are somewhat vague and circular. That may be one reason OSHA rarely cites employers for unqualified trainers. However, if operators are not learning, remembering, or following their training, you might need to take a closer look at your operator training and evaluation program – along with a look at the trainer. For related information, see our article Considerations when designing practical training for PITs.
Evaluate your training materials, program, and trainer(s) to ensure that you’re delivering comprehensive training and that operators actually follow their training. If an operator remembers the training but ignores the rules, that’s an operator issue. However, if an operator cannot remember what was covered in training, or if a topic wasn’t covered at all, that’s a trainer or training program issue.
Key to remember: The employer determines whether someone is qualified to train forklift operators. Although OSHA rarely cites for lacking qualifications, OSHA does frequently hold employers responsible for training shortcomings.
