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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
here in the uk we are pretty tightly regulated with any one who wants to train other operators having to be certified to instructor level. thats normally a two week course for cb and reach truck. the way insurance companies try to find somebody to put the blame on, any one who is even thinking about training other operators would be best advised to do as alabama says, follow the best practice you can, keep records, do your refresher training, have public liability insurance and just hope that the majority of the people you train will remember the training. some certainly wont.
I believe no matter what guidelines or regulations that are set by osha and no matter how good the training is, there will be operators that will break the rules and cause accidents, even competent operators. There always will be great liability in training operators and statistic's show that the majority of the accidents were due to operator error, not following the rules set by their employer, failing to sound their horn, overlifting and etc. Not to say it can't happen, though I have not heard of a case where a trainer was faulted and charged for an accident that happened by an operator that he or she has trained. I believe if you follow the guidelines set by osha, keep good records, only certify competent operators and give the best and most detailed training you can, you most likely will not have something come back to haunt you and your employer and if it does you hopefully will have records to prove your innocence.
Then again, how often are the rules, or laws, updated. The CSA in Canada, which is NOT a legislative body, whom the Ministry of Labour in the province of Ontario tries to enforce, updates their safety guidelines every 10 years. WOW!!!!
I was told that TTT expires when OSHA updates the rules surrounding forklift safety in the OSHA Manual. The instructor told us that is happened many years ago and it caused a huge surge to his course.
RESPONSE TO: Feb-18---dan M--- I would like to see that program implemented here in the STATES.
RESPONSE TO : dan M--- I appreciate your feedback on this subject, I believe that there needs to be more specific and stringent guidlines for trainers and for training. All of the literature you read is vague. I agree with you completly about the "quickie" training sessions, i t happens all the time and most folks have forgotten what you have shown them--the training needs to be more rigorus and detailed and not with just one type of equipment--If an operator will be using a sit-down CB truck and a reach-truck, He should be trained on each one, and not for just a few minutes, a day for each truck. Fewer accidents and injuries would result and less damage to products--Getting Management to do this might be a problem.
RoadRat,
TTT is common, and I am sure your company does a fine job. Now, once you leave, does that indivdual prepare for each course? Does that individual remember what your company has taught him a few weeks ago? Will that in-house trainer take the time to go through everything thoroughly, or cut it short because of an impromptu meeting, or just show the staff what the three control levers do, and how to steer the truck?
I do not know, but do you? I guess it is out of your hands at that point, but all we have is the blind leading the blind.
Dan
Most forklift companies can do certifications. Train the trainer is a common thing we do for are customers.
Dan, etharp.
Your right Dan you dont know me, so you wondering if I am capable of being able to train someone is irrelevant. I am fully aware of my strenghts and weaknesses and since you don't know me I dont know why you keep inquiring. I am not trying to be rude, it is that no one seems to have a definitive answer, and honestly I am not sure there is one. I have read the osha interpretations on drivers training, which has some holes in it. I was have been inquiring on the different ways it has been interpreted from everyone that has posted so I can compile the info and make it an effective and legal tool for my employer. Etharp thanks for the post on the insurance, and insurance will not be a problem. After all the posts concerning this issue, I know I will get as much training as possible before I jump into it. After serving 12 years in the U.S Army, saftey and training have always been important. Thanks for your posts.
Alabama,
I do not know (you) whether you are qualified or not to educate others on the merits of operating lift trucks in a safe and efficient manner, but you must ask yourself the following questions:
1. Can you design programs that impact your students, and design programs that are uniquely your own?
2. Can you set standards for all your participants, live by those standards, and not deviate from those standards?
3. Are you confident enough to stand-up in front of a class, deliver your presentation without any ums and uhs, and answer questions without hesitation, and with convincing confidence?
4. Are you willing to accept any liability for not fulfilling the needs of your students because of ineptness?
5. Do you feel, do you know, whether you have the knowldege, training and experience to train others to minimze any misfortune that may descend upon them?
Maybe you do...Maybe you don't. Only you can judge for yourself, and then accept the liability.
Dan
I dont know Dan, something of such importance should not be so vague or indirect. Thats why I have been so inquisitive with the interpretations that osha states. Maybe it gives them some wiggle room if something happens. Good question though, looking forward to see all the posts on this one.
It always amazes me that the OSHA guidelines, or the Ministry of Labour Ontario require a trainer who possesses the knowledge, training, and experience...........Why would online courses, or CD courses qualify as competent persons?
Joseph, Thanks for the post. Some of the past post's I feel there are some out there who think that I have had a 1 day class on drivers training in 2005 and now I think that I am Captain Trainer and Im ready to train the world. Well honestly I cant blame them for thinking that way since I have not explained my background. Now Iam sure there are many of you with a more extensive background and has far more experience than me, so I humbley explain. I have 13 years in the material handling industry as a field service tech with a couple of years in sales. I would never claim or bragg to be the best at what I do, there is always room for more training and improvement. I have worked on most all brands and class trucks and I have a pretty good idea how they operate. I have worked for some very good companies who strive on training, in which I always welcomed. I would never offer a service that i was not capable or not trained properly to provide. I was only inquiring the legalitys of how one is trained before one can legally provide such a service. It looks like the standard Osha interpretations does not require that someone has to be trained per-say but must have the knowledge, training, and experience to train PIT's. Now with that said, before I make my own interpretations I will call Osha myself to get the clarification to ensure I do whats right and LEGAL for my employer. I have appreciated all the posts wether I agree or disagree, It lets me realize that ther are people all around the globe who are willing to help and give advice to someone they do not know. Thanks !!!!
Alabama:
The following statement is made by OSHA in its Standard Interpretations:
" §1910.178(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. There is no requirement that the trainer attend a train-the-trainer course. However, you may find it useful to have trainers attend such a course."
Google: 04/10/2000 - COMPETENCY OF POWERED INDUSTRIAL TRUCK TRAINERS
The best source for a direct answer to your question would be your closest Illinois office of the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA).
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