- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
August 23, 1999
Mr. George A. Miller
Mason Contractors Association of America
1910 South Highland Avenue Suite 101
Lombard, IL 60148
Dear Mr. Miller:
Thank you for the invitation to review the complete set of materials for the Mason Contractors Association of America (MCAA), Rough Terrain Forklift Training Course. Although OSHA cannot endorse or approve any product or services, we are pleased to evaluate the training materials you provided and to advise you if they meet the intent of the standards.
The five sections of this Rough Terrain Forklift Training Course address each section of OSHA's, "Powered Industrial Truck Operator Training" standard as published in the December 1, 1998 Federal Register. The sections cover, in a way that is easily understood, the skills and knowledge necessary for an operator to safely operate a "rough terrain" or "heavy" powered industrial truck.
- The "Administrators' Guide" contains recommendations that all instructors would find useful for conducting the sessions, assisting the students, training supervisors, and testing for retention and practical skills. It also provides guidance for periodic skills retraining and student progress determinations.
- The "MCAA Rough Terrain Forklift Safety and Maintenance Training Manual" (Classroom Section) parallels the information in the "Rough Terrain Forklift" video. The programmed learning sequences in the manual uses pictures and text from the video on the same page as the practice test questions and answers. The review quiz that follows each major section reinforces the safe work procedures and skills for each section.
- The video summarizes all the material in the manual and with actual photographic sequences and graphics illustrations that further explain topics such as vehicle stability and steering. A variety of working conditions showing safe and unsafe operations helps to reinforce the written text.
- The "MCAA Rough Terrain Forklift Safety and Maintenance Training Course" (Hands on Test) provides the instructor with guidance for the evaluation of the operator. The proficiency check sheet addresses details for the safe operation of the vehicle such as the use of seat belts; understanding load charts and rated loads; inspections of gauges; adjusting to specific site conditions; traveling; lifting; etc. The requirement to pass the section containing load charts and warning labels, without an error exceeds the OSHA standards and clearly conveys the importance of safe vehicle operation.
- The "Qualifying Examination" questions are a general review of the major skills and safety issues that an operator must know to work in a safe manner. The requirement for a passing score of 80% indicates a commitment to quality training.
The training package you submitted combines text book training with "hands on" skills. All of the topics contained in OSHA's current "Powered Industrial Truck Operator Training" standard are addressed by this program.
You enclosed with your letter an article from SMAC, the magazine of the Sheet Metal and Air Conditioning Contractors National Association (SMACNA), reporting that OSHA has endorsed a pilot training program they are developing. The article is misleading. The OSHA Training Institute currently trains and certifies public and private instructors to present the OSHA 10-hour Construction course and to issue cards to the students certifying that they have completed the course. OSHA has simply agreed to evaluate the program SMACNA is developing to deliver this training to their members through the use of multi-media technology and remote access. Our purpose is to assure that the material is consistent with that delivered in the courses presented on site by certified instructors. We will also evaluate the effectiveness of this method of delivering the training to students. I hope this clarifies our policy for you.
If you have any questions please contact Mr. Thomas Marple at 202-693-2020.
Russell B. Swanson
Directorate of Construction