CFR1910.178(l)(2)(i) Trainees may operate a powered industrial truck only:
CFR1910.178(l)(2)(i)(B) Where such operation does not endanger the trainee or other employees.
So it seems to me that testing in the exact area of operation is not such a wise thing to expect, and the use of safety cones is preferred over operations in an area where the standard dangers of the workplace exist.
In fact, it reads to me that as long as they are "trainee" they may NOT operate in the workplace, and only after demonstration of familiarity with the machine and having had a walk though that identified the actual workplace (site specific) hazards should they be allowed to operate "in the workplace".
You quote "an evaluation of the operator's performance in the workplace" which is not the same as; "practical training (demonstrations performed by the trainer and practical exercises performed by the trainee".
It seems to me that the "hands on" section to be the "Practical exercises". and evaluation of the operator to be after the trainee is declared competent to be an operator.
I hardly ever think that I (as the trainer) can spend more than 30 minutes with a trainee per type of machine and attachment, for the "practical exercise" and the time the operator must spend to become "expert" is more something their supervisor will spend with them.
I would have to agree there is no way I could consider 2 to 5 minutes anywhere near the requirement "to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely", which I do not see as rigorous as "competence", especially since the operator must demonstrate they know how to do [CFR1910.178(l)(3)(i)(J)] "Any vehicle inspection and maintenance that the operator will be required to perform. "
Can you check the oil, look for leaks, check to make sure the wheels are not falling off, and operate the hydraulic functiuons completely on your forklift in under 2 minutes?
your mileage may vary.
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