Stay current on EPA rules and regulations by visiting the EPA web site here:http://www2.epa.gov/laws-regulations. They list regulatory information by topic and by industry sector. It beats reading the Federal Register to glean pertinent environmental law information.
In this post, we examine forklift training and who is qualified to train forklift operators. There may be some confusion about who may instruct forklift operators. What does the OSHA standard require? 29 CFR 1910.178(l)(2)(iii) states: 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. According to OSHA’s interpretation of the Standard:
“A trainer must have the “knowledge, training, and experience” to train others how to safely operate the powered industrial truck in the employer’s workplace. In general, the trainer will only have sufficient “experience” if he has the practical skills and judgment to be able to himself operate the equipment safely under the conditions prevailing in the employer’s workplace. For example, if the employer uses certain truck attachments and the trainer has never operated a truck with those attachments, the trainer would not have the experience necessary to train and evaluate others adequately on the safe use of those attachments. However, the standard does not require that the trainers operate a PIT regularly (i.e., outside of their operator training duties) as part of their job function or responsibility.”
More about the standard and forklift operator training:
The standard requires employers to develop and implement a training program based on the general principles of safe truck operation, the types of vehicle(s) being used in the workplace, the hazards of the workplace created by the use of the vehicle(s), and the general safety requirements of the OSHA standard. Trained operators must know how to do the job properly and do it safely as demonstrated by workplace evaluation. Formal (lecture, video, etc.) and practical (demonstration and practical exercises) training must be provided. Employers must also certify that each operator has received the training and evaluate each operator at least once every three years. Prior to operating the truck in the workplace, the employer must evaluate the operator’s performance and determine the operator to be competent to operate a powered industrial truck safely. Refresher training is needed whenever an operator demonstrates a deficiency in the safe operation of the truck. Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator’s performance in the workplace. [29 CFR 1910.178(l)(2)(ii)].
For additional information, see: https://www.osha.gov/SLTC/etools/pit/assistance/
Some brief thoughts about your relationship with regulatory agencies. They are designed to administer environmental, health and safety regulations. Most often, your interactions will be with local (city and county) or possibly State agencies. Your job is to develop a good working relationship with your regulatory agency partners and that means treating your inspector courteously. However, as with any profession, regulatory inspectors come with all levels of proficiency. If you disagree with an inspector’s findings in the field or feel compelled to correct them it they are in error, be kind and patient and if need be, wait for an opportunity to express your position with their superior. No need to antagonize the inspector that you work with and probably will see for years to come. There may be times when you do not agree with one regulatory requirement or another, but don’t vent to the inspector or complain to the agency. If you feel strongly about changing a regulatory requirement, work with your legislators and perhaps an industry organization with a potent lobby resource. Laws can be changed but it takes time. Meanwhile, understand and abide by your regulatory requirements. Be forthright and do not attempt to conceal or mislead an inspector either for that behavior may come back to bite you.