I enjoyed reading the comments from everyone. One last little piece from a letter of interpretation from OSHA is below and further clarifies what it may take to train on certain type of lifts or attachments. It would have been easier and better if they have laid out specific trainer criteria in the standard, but at least this helps:
Background: 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.
Scenario: Driver instructor examiners are training some powered industrial truck (PIT) operators. The driver instructor examiners have been certified to teach PIT operator training, however they do not operate PITs on a regular basis or as part of their job function and responsibility.
Question: What does OSHA mean by the word "experience" in 29 CFR 1910.178(l)(2)(iii)? Specifically, does it mean that the trainers must be certified to train drivers to operate PITs, or does it mean that the trainers must operate PITs on a regular basis as part of their job function and responsibility?
Reply: 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.
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