I also have check with local training center, their comment is to follow OSHA standard,
My operation team is operating 1.6T electric counterbalance forklift with standard duplex mast, closed mast height of 2.1m. Travel speed set to 7km/hr. The mast thickness does not obstruct much of the driver visibilities. The theory part only mention travel with load on ramp, but did not mention travel without load.

Is it compliance that I conduct an risk assessment to evaluate this process and document it?