Wow, what a thread, I should have gotten in on this a long time back! Some related comments from a OSHA document I use from time to time are below, they speak to trainer's qualifications slightly better than the standard, but not much. They do, however, clear of the issue of who can "certify" operators. I agree we must watch for people claiming to be OSHA certified or OSHA approved, many of these people are just ignorant, not deceptive, but that is not true of all, some do it on purpose for marketing reasons. A few other comments before I turn it over to OSHA:
1) Don't expect ANY changes in the OSHA forklift standard before you retire, it is not going to happen. It took 10 years to get wha we have now.
2) If you want to know why they chose the language they did for trainers and why they did not go further, read the Federal Register for that time period, it has all the sorted arguements. You can agree or not, but it is all there.
3) In the end I think the trainers in the fall in like this. There are a lot of hacks that claim they are a trainer and don't do any more than put in a DVD or video and do a joke of a hands on test, I could hire a money and a talking parrot to do that. There are many, many decent trainers out there that do a good job day in and out, they don't have big egos, they are just doing the job, not fancy but well. There are a small number of elite trainers out there setting the world on fire, with neat programs, pushing the limits, etc.
4) Anyone can be sued for anything, even if they did nothing wrong. As a trainer you better have good E & O insurance and do things as correctly as you can, plus document the heck out of what you do.
Off my soap box and on to what OSHA says below:
DIRECTIVE NUMBER: CPL 2-1.28A EFFECTIVE DATE: NOVEMBER 30, 2000
SUBJECT: Compliance Assistance for the Powered Industrial Truck Operator Training Standards
Point One:
Training, Evaluation and Certification by a Third Party. The person or persons who conduct training, refresher training, evaluations, and certification of operators under 1910.178(l) need not be employed by the employer of those operators. Such third-party training, including appropriate on-the-job training, may be provided by an employers' association, a labor union, joint labor-management training organization, or any other organization meeting the requirements of the standard. However, citations for failure to train will always be issued to the employer.
The employer may rely on a third-party trainer's certification that an employee has been trained and evaluated to operate a particular type of powered industrial truck in accordance with the standard if the training entity presents to the employer verification that the training program conforms to the standard and includes a list of topics covered by the training. The employer must make the verification available to OSHA upon request.
If a powered industrial truck operator is certified under the preceding paragraph, the employer must provide additional training in any of those topics only when its powered industrial truck operators will be potentially exposed to hazardous workplace-related conditions that could not reasonably have been foreseen when the training took place. Before employees operate powered industrial trucks under these conditions, the employer must brief them about the conditions and how to operate the powered industrial truck safely under those conditions.
Point Two:
Paragraph (l)(2)(iii) requires that all operator training and evaluation be conducted by a person who has the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.
How could an employer determine the qualifications of trainers?
An example of a qualified trainer would be a person who, by possession of a recognized degree, certificate, or professional standing, or who by knowledge, training and experience, has demonstrated the a
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