Budcoh, when my customer's people complete my training they get the Training Card & Wall Certificate. They also get a complete list of everyone that was in the class with grades for classroom portion and hands on portion. Along with all of this, they get the students workbook to keep on file, which shows that the training is formatted according to OSHA's 29CFR 1910.178. If this isn't enough for any OSHA representative, they are welcome to discuss all of the training with me as their 3rd party Trainer.

Thanks for the compliment budman. However, although I didn't state it clearly enough, my point was that employer/users who rely on a 3PL to do their training should require hard copies of the training for their own files and not relay solely on the 3PL. If you read the records I referenced, you'll see that Jurgen produced copies of their powerpoints, lesson plans, etc. They had it dead nuts cold no if, ands. or buts. No penalties/fines.

Great points made budcoh. As a Trainer. When I bill the training out to my customers, it's all on the invoice. What type of training, who attended the training, dates of the training. We can go back indefinitely and pull records/ invoices with this information. I also keep hard copies in my files. You can never be too safe!

If you want to know why you should maintain and keep documentation, Google John R. Jurgensen Co. Butler County Ohio. They had a fatal accident 4 Sep 2010 and OSHA issued 3 serious citations. The company beat all 3 citations because it was able to produce documentations of its training. Also see secretary of Labor v. John R. Jurgensen Co. OSHRC Docket No. 10-2646, 7/23/12. Although 1910.178 requires only one document - the certification - any trainer who doesn't keep copies of OSHA's "implied" documentation requirements is a fool. DIRTFT

ok budman
so i can take that as a no...

but i'd like to hear from it's owner

i'm sure they won't certify it so they won't have any liable tie to it ;o)

Swoop223 I've been told many times by OSHA & their representatives that they do not approve any training program above any other. As long as the program meets the Standard 29CFR 1910.178, it is accepted.

there is no 'official' software to keep records of 'certification' training
it is all done inhouse with companies and thier own trainers in what ever method they use to do it. And generally done the cheapest way possible as long as it gets done and the certification cards are handed out ;o)


and as for ssts123 and his 3d training program?
has this program been approved and certified by OSHA to be used as a training program?

Joe_m We provide a 3D Forklift Trainer software solution that provides training modules based on OSHA standards. The software can track each operator and what modules were completed and how well they performed. For more information - streamlinesimulations.com

As an outside trainer, I maintain the following items on my PC indefinitely:
Record of Training
Pics 'n permits (digital versions)
Invoices

Actual test copies that I do not turn over to the client are maintained in my office for three years, then tossed out. However, the Record of Training does indicate the incorrect responses along with the correct answers for the supervisor to review.

Maybe this will help - a direct copy & paste job of the initial OSHA requaltion on industrial (vs. construction related)F/L operator training:

"Operator training.
1910.178(l)(1)
Safe operation.
1910.178(l)(1)(i)
The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l).
1910.178(l)(1)(ii)
Prior to permitting an employee to operate a powered industrial truck (except for training purposes), the employer shall ensure that each operator has successfully completed the training required by this paragraph (l), except as permitted by paragraph (l)..........................................>>>>>>>>>>> "

Edward T, I do not doubt this. I couldn't locate this exact OSHA Interpretation. But as a Dealer Principle, I keep records of all of my Training. But I do not control it after the training. It's the customers responsibility to keep up with their operator's and when they are due to go through the training again to stay in compliance. It's also their responsibility to police their operator's on near misses or if they have to have refresher training due to an incident. But if OSHA comes in and request when someone has last been trained, I can show proof in my records, but the customer has the operator's workbook of the class he had taken. I'm not sure if this is whaTt the original question really was. The gentleman that ask it is not a customer, but is from a training organization.

/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23346

osha dot gov site,,,
quote OSHA's official reply to the question...
You further ask who must maintain the training and certification records. Paragraph (l)(6) does not specify who must maintain the records; however, the employer is ultimately responsible for ensuring the availability of these records. Third-party trainers who agree to maintain the records would also need to ensure their immediate availability to the employer.

Gotta' agree with the Budman on both his posts.
Going back to my days in Dealer Training when we were developing Operator Training Programs & Train-The Trainer Programs I recall that: Only the employer is in the position to "police" an operator and pull his permitting (aka certification), if necessary. And part of the complete training is to evaluate the operator's skills in the work environment where they will be actual working and isolated from other employees - no OJT and if they are moved to another area that requires different skills they need to be re-evaluated.

Edward T: I would like to know where you are reading this from? Osha states in 29CFR 1910.178:

1910.178(l)(1)(i)
The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l).
1910.178(l)(1)(ii)
Prior to permitting an employee to operate a powered industrial truck (except for training purposes), the employer shall ensure that each operator has successfully completed the training required by this paragraph (l), except as permitted by paragraph (l)(5).

1910.178(l)(2)(iii)
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.
1910.178(l)(3)

No where in the Standard can I find that it is the Instructor's responsibility to maintain these records. Only that the Employer is responsible to make sure that their employees are trained under the standard. I've been in the Business for 25 yrs and Training for most of it.

as I read the requirements from OSHA, it looks to me like it is the -trainer's- responsibility to retain the training records for a three year period, not the employee/operator but the trainer,as well as the employer, especially if the trainer is an outside contractor..