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 https://www.osha.gov.

April 10, 2000

Mr. Bob Mundson
Mitsubishi Caterpillar Forklift America
2011 W. Sam Houston Pkwy N.
Houston, Texas 77095

Dear Mr. Mundson:

Thank you for your November 2, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs (DEP)]. Your letter has been referred to the [Office of General Industry Enforcement (GIE)] for an answer regarding OSHA's powered industrial truck standard. Your specific question has been restated below for clarity.

Scenario. A Train-the-Trainer class for dealers and customers consists of teaching potential powered industrial truck instructors how to prepare for classes and use materials in their training efforts. In addition, these instructors are trained as operators by going through the program from start to finish. There is a hands-on portion of the class, where the potential instructors operate a powered industrial truck on a general obstacle course, testing them on maneuverability, lifting and traveling with and without loads, parking the truck, and a pre-shift inspection. This gives the potential instructor a general idea of how to use the truck and familiarity with basic truck maneuvers. Attendees who successfully pass the course receive a trainer's certificate, an operator's certificate and a wallet card.

Question. Is this general course and hands-on training acceptable under the new OSHA regulations for operator training of powered industrial trucks, if it is not truck or site specific?

Response. §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.

In terms of powered industrial truck operator training (i.e. for the operation of the powered industrial truck itself) - this course would not be acceptable unless the training program content covered the truck and workplace-related topics listed at §1910.178(l)(3)(i) and (ii) respectively. As stated in your letter, this course is attended by several dealers and customers whose sites have a variety of different truck and workplace conditions. The course as described in your letter appears to assist attendees in developing their own powered industrial truck operator training program. The students are run through a hands-on operator training aspect of the course for the purposes of familiarity with basic truck maneuvers. It is unlikely that such a basic course could encompass all of the individual truck-related and workplace-related conditions necessary for the safe operation of the powered industrial truck.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at
http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement at (202) 693-1850].


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]