Regulations (Preambles to Final Rules) - Table of Contents Regulations (Preambles to Final Rules) - Table of Contents
• Record Type: Powered Industrial Truck Operator Training
• Section: 6
• Title: Section 6 - VI. Training

VI. Training

Training provides a person with the necessary specialized instruction and practice to become proficient at a particular task. Training is the means by which an employer ensures that employees have the knowledge and skills they need to do their jobs correctly and safely. The alternative to formal training is learning by trial and error, an approach that results in an inadequate knowledge base and relies on mistakes (which often involve accidents, injuries, and near-miss incidents) for learning to occur. Reliance on this approach would create a greater chance of injuries and fatalities.

After employees have received initial training, acquired the basic knowledge, and perfected their operating skills, the employer may rely on refresher training to reinforce or improve the employee's knowledge of the basic training material; to impart new information; to teach material in a new manner; or simply to maintain an acceptable level of awareness of workplace conditions, operating hazards, and truck-related characteristics.

There are several approaches to assembling the necessary materials and methods for an effective training program. One approach is to make use of existing literature and model programs already developed. Another approach is to look at problems that occur during ongoing operations and identify what an operator must know to avoid or otherwise minimize the potential for an accident due to those problems.

A third approach to developing a training program is to analyze the accidents that have occurred and develop a training program that will minimize the potential for a recurrence of the conditions that caused the accident. A problem with this third method of program development is that it is reactive rather than proactive, i.e., tends to emphasize the problems that have caused an accident (the training is in reaction to an accident). By contrast, proactive training teaches employees to prevent accidents rather than waiting for accidents to occur before recognizing the need for the training and determining what the scope and content of the training should be.

According to one hearing participant, a professional trainer (Tr. p. 129):

In principle we are in support of the proposed training rule. The key issue as we see it is that any prescribed training has to be both effective and efficient. Our viewpoint is that the need for prevention of accidents among lift truck operators is not arguable but we also believe that the current rule is ineffective. Additionally, our view is that the final rule must use what is at this time, common knowledge among the professional training community in the United States regarding effective and efficient training strategies. For the purpose of clarifying our testimony, we're defining operator training as instructional or other influence strategies used to help operators learn to change their on-truck behavior. We believe that effective training of operators is that which results in fewer injuries and fatalities. In that regard, the most important issue for the training rule to address in our viewpoint, is not to just require traditionally accepted training strategies but to require operator training strategies that actually transfer to the operating environment.

Another benefit of proactive training is that the person observing the worksite and the work being conducted to develop a training program for powered industrial truck operators may identify other problems in the workplace and offer solutions to those problems. Identifying and resolving these other problems can reduce the total number and/or severity of accidents in the workplace, not only those related to powered industrial truck use but also those associated with other workplace activities. According to another hearing participant (Tr. p. 425):

Our processes include an evaluation of the facility and recommendations for improvement. We do not pass a problem within a company without trying to correct that problem before the training is implemented.

The training requirements in the final rule reflect all three approaches discussed above. They require training in specific topics unless a particular topic is not relevant to the types of vehicles or the employer's workplace. They require the training to address topics specific to the employer's workplace and to cover information learned from accidents or near-misses that have occurred in the employer's workplace. As discussed below, OSHA believes that this approach will result in operator training that is most effective in reducing truck-related deaths and injuries.

The topics OSHA requires to be covered in the training mandated by this standard can also be used to evaluate the effectiveness of a powered industrial truck operator's training. For example, an employer can use the list of required topics to determine what should be taught and then compare that with what is being taught. In this manner, employers can ensure that the training is appropriate for the types of trucks being used and the conditions in the workplace that affect the safe operation of those trucks.

Training comes in many forms. It may be as simple and informal as a supervisor discussing the correct way to operate a vehicle, correcting an error in the way an employee is doing a job, or showing an employee how to perform a particular task properly. Alternatively, training may consist of detailed, structured instruction using formal training methods (e.g., lectures, formal demonstrations, practical exercises, examinations, etc.). Formal training is usually used to provide trainees with a large amount of information. OSHA believes, and the record confirms, that a combination of training methods is most effective in training powered industrial truck operators.

For the most part, employees do not start out with the knowledge and skills they need to operate a powered industrial truck safely. Although many employees selected or assigned to operate powered industrial trucks are licensed to drive automobiles, there are enough differences between these two types of vehicles and their operation to require additional knowledge and skills to operate a powered industrial truck safely. For example, industrial trucks, compared with cars, have limited forward visibility when carrying a large load, have rear wheel steering and front wheel drive, have different centers of gravity and balance, have different control configurations, and can carry heavy loads with the weight concentrated at one end of the vehicle. Employees need formal training and practice to gain the knowledge and to master the skills they need to safely operate powered industrial trucks with these characteristics.

Effective employee training and supervision also can lessen the frequency with which employees perform unsafe acts such as speeding, failing to look in the direction of travel, and failing to slow down or stop and sound the vehicle's horn at blind intersections and other areas where pedestrian traffic may not be observable. This, in turn, reduces the frequency and severity of accidents.

Another case where training can prevent accidents or lessen their severity is when powered industrial trucks travel with an elevated load. Effective operator training must emphasize that the operator moves the vehicle only when the load is at its lowest practical point. In addition, even if a sit-down rider truck operator fails to follow this practice and the vehicle tips over, both the chance and severity of injury are reduced if the operator is trained to stay with the vehicle and lean away from the direction of fall. When a sit-down rider truck tips over and the operator attempts to jump off the vehicle while it is tipping over, the operator is often crushed when struck by the overhead guard. In these cases, since the normal tendency is for a person to jump downward, the operator lands on the floor or ground in the path of the overhead guard, and receives a crushing injury to the head, neck, or back. Training an employee to stay with this type of vehicle and lean away from the direction of fall will reduce the severity of or eliminate these injuries.

On the other hand, when a stand-up rider truck tips over laterally, the operator must be trained to step off the vehicle toward the rear of the vehicle. The operator can safely do this because he/she is not moving in the direction in which the truck is falling, but rather is moving perpendicular to the direction of the vehicle's fall.

The studies conducted by Cohen and Jensen, discussed under Studies of Accident and Injury Data and of Training Effectiveness earlier in this preamble, found that training reduced operator error rates by as much as 70 percent. Although a 70 percent error rate reduction does not necessarily correspond with an equivalent reduction in the number of accidents that a given group of operators will experience, improper or unsafe operation of powered industrial trucks is clearly the major cause of accidents and their resultant fatalities and injuries. Therefore, reducing the number of unsafe acts that are committed when operating these trucks will reduce the number of accidents, fatalities, and injuries.

Proper employee training must take into account different operating conditions (including the type and size of the load, the type and condition of the surface on which the vehicle is being operated, and other factors that can adversely affect vehicle operation). Operator training must emphasize two points regarding potential accidents: (1) the employee must not engage in activities that will increase the potential for an accident to occur; and (2) the employee must take appropriate action to minimize the potential for injury to himself/herself or to other employees if an accident occurs.

OSHA's current powered industrial truck training standard (codified at 1910.178(l)), has a very general training requirement. It states:

Only trained and authorized operators shall be permitted to operate a powered industrial truck. Methods shall be devised to train operators in the safe operation of powered industrial trucks.

As discussed above, this provision has not been adequate to reduce the large number of fatalities, accidents, and injuries caused by untrained or poorly trained operators. Consequently, OSHA proposed more extensive training requirements to improve operator training (60 FR 13782, March 14, 1995, and 61 FR 3094, January 30, 1996).

There were 64 commenters who discussed the need for training powered industrial truck operators (Exs. 7-1, 7-5, 7-8, 7-10, 7-19, 7-22, 7-28, 7-29, 7-31, 7-32, 7-34, 7-36, 7-38, 7-39, 7-40, 7-43, 7-45, 7-46, 7-47, 7-48, 7-49, 7-50, 7-51, 7-59, 7-66, 7-67, 7-69, 7-71, 11-1, 11-2, 11-6, 11-12, 11-13, 11-15, 11-17, 11-18, 11-19, 11-22, 11-25, 11-27, 11-29, 11-31, 11-35, 11-36, 11-40, 11-41, 11-44, and 11-46; Tr. Pp. 22-24, 27-29, 35 and 44, 49, 62, 75, 94, 129 and 143, 172, 196, 306, 331, 340, 383, 398, 416, 443). The great majority of these commenters agreed on the need to train powered industrial truck operators.

For example, one commenter (Ex. 7-66) stated:

The WGMA [West Gulf Maritime Association] supports operator skill and safety training for powered industrial truck operations. We have for years had operator training and certification requirements for certain equipment. These requirements are part of our collective bargaining agreement between management and labor.

A second commenter (Ex. 11-2) stated:

AGC [Associated General Contractors] believes that worker training is the key to worker protection and AGC commends OSHA for its recent emphasis on powered industrial truck operator training.

A third commenter (Ex. 7-34) said:

In general, Dow agrees with OSHA that there are risks associated with the operation of powered industrial trucks and that those persons operating them must be knowledgeable and skilled prior to being authorized to operate the vehicle. Dow believes that the training its people receive on these vehicles has been adequate. As a result, comments will focus on retaining the performance language in this training so that we can continue the success we have had thus far.

One commenter (Ex. 7-48), however, expressly disagreed that there is a need for OSHA to issue a standard for training powered industrial truck operators. It stated:

Overall, UPS [United Parcel Service] questions the need for a standard regulating the training of powered industrial truck operators. UPS has never experienced a noteworthy amount of workplace accidents involving powered industrial trucks. We do not expect that implementation of this type of standard will reduce the already low number of accidents in this category. This proposed standard would substantially increase costs to employers without a corresponding reduction in injuries, providing little justification for its implementation. As such, UPS cannot support the promulgation of this standard.

Many commenters generally supported OSHA's proposal to make the training requirements more explicit. For example, one commenter (Ex. 7-29) stated:

UTC [United Technologies Corporation] agrees with OSHA's stated purpose "to amend the current powered industrial truck operator training requirements for general industry and to adopt the same requirements for the maritime industries", which will eliminate redundant standards for separate industries. In addition, UTC approves of OSHA's approach in mandating "the development of a training program that would base the amount, type, degree and sufficiency of training on the knowledge and the skills and abilities that are necessary to safely operate the truck" rather than mandating specific universal training requirements that would not take into consideration the variety of truck, necessary operator knowledge and training levels, and operating situations.

Overall, OSHA's proposed changes to the original 1971 powered industrial truck standard are reasonable and provide a sound basis for enhancing the safe operation of powered industrial trucks in the workplace while allowing a maximum of flexibility in the methods employers may select for implementation.

A second commenter (Ex. 7-31) stated:

As an association, we [American Warehouse Association] have urged our members to adopt training programs. One member reports that although one-third of the accidents in the warehouse were lift truck-related, one-half of the costs associated with accidents were lift truck related. Although this example is just a snapshot of the industry, this anecdotal information confirms that proper training is in the best interests of our industry.

It is appropriate to consider revising the existing OSHA regulations. A more defined standard will be of benefit to both employers and employees. However, as our comments will suggest, the revised standard need not be overwhelming or unnecessarily complex to achieve the desired result.

A third commenter (Ex. 7-36) stated:

API [American Petroleum Institute] generally supports the standard proposed by OSHA, with minor revisions, to replace the existing requirements under 29 CFR 1910.178(l) and to be added as new requirements under 29 CFR 1915.120, 1917.43, and 1918.77, provided the proposed standard remains performance oriented. Powered industrial trucks vary greatly in configuration and application, making operator training requirements very site specific. Accordingly, API supports OSHA's development of a flexible, performance based standard that will allow each facility to best address the specific training needs of operators at that location.

Finally, one commenter (Ex. 7-28) said:

NAWGA/IFDA appreciates the concerns that have led OSHA to propose this rule, and believes that benefits can flow to companies and their workers through the dissemination of guidance on appropriate training for employees who operate powered industrial trucks. While we have comments and suggestions regarding certain aspects of the proposal's requirements, our organization believes that many of the training elements noted in the rule are appropriate topics to be covered in the instruction provided to powered industrial truck operators.

Some commenters opposed changing OSHA's existing training requirement (Exs. 7-1, 7-5, 7-6, 7-8, 7-19, 7-20, 7-22, 7-27, 7-28, 7-33, 7-34, 7-38, 7-40, 7-69, 11-7, 11-15, 11-16, 11-20, 11-23, 11-35, 11-42, Tr. pp. 121, 151, 246). One reason given for not changing the existing requirement is that it is written in general language and therefore allows employers complete freedom to tailor their powered industrial truck operator training program. These commenters generally stated that they already conduct the appropriate operator training. For example, one commenter (Ex. 7-8) stated:

The proposed training requirements that would mandate the development of a training program that would base the amount, type, degree and sufficiency of training on the knowledge of the trainee and the ability of the vehicle operator to acquire, retain and use the knowledge and skills and abilities that are necessary to safely operate the truck would require quite a bit of additional time and categories of paperwork and would be, in many instances very subjective and difficult to document. The basic requirements that presently exist are quite sufficient and any safety professional worth their salt is going to look at the things you are proposing anyway.

Some of these commenters also suggested that the proposed standard, if adopted, would create too structured a program and would be overly burdensome to the employer. For example, one commenter (Ex. 7-19) stated:

Current regulations, 29 CFR 1910.178, have provided Mobil and other companies like Mobil sufficient direction and discretion to develop and implement effective training processes for its powered industrial truck operators. Mobil is concerned that the more detailed nature of these proposed regulations will require costly changes to currently effective training processes.

Other commenters stated that OSHA's proposed training requirements were appropriate and not overly burdensome. For example, one commenter (Tr. p. 418) stated:

I * * * commend your efforts and give you my profound support. Your proposed rules were well researched and, if passed into law, will assist industry leaders by providing the needed guidelines to develop, implement and follow up their operator training programs * * *

From our company's conception in 1987, it was apparent that our present occupational safety at 1910.178 Code of Regulations for material handling and storage did, in fact, supply some foundation for training materials content, but did not supply enough direction to allow the meeting of the minds within a single company.

Although there was a starting point, technical advances have caused tremendous pressures on our industries, manufacturers, as well as the end user.

New problems were identified as a result of these advances that never had to be addressed in the past. Professionally, I believe that the proposed rules are on target and will prove to be a sufficient step forward in providing guidelines and benchmarks for industries.

Another commenter (Ex. 7-17) stated:

I also believe that inadequate operator training and supervision are the cause of the great majority of industrial truck accidents. Your proposed rule change therefore not only has the potential to substantially reduce the number of fatalities and serious accidents that occur each year; it also has the potential to reduce the large number of unreported accidents and near-misses that occur every day. It is a step in the right direction that should be applauded.

Several representatives of the longshoring and marine terminals industries, however, opposed the proposed rule (Exs. 7-43, 7-46, 7-63, 11-7, 11-20, 11-42, Tr. p. 246). These commenters contended that they already have regulations that cover powered industrial truck operator training (Secs. 1917.27(a) and 1918.98(a) respectively) and that those regulations have served their industry well. Indeed, one commenter claimed that there were few powered industrial truck injuries or fatalities in the industry. (See Tr. p. 248.) According to this commenter:

Again, there is no proof of a significant risk to injury to employees to warrant this additional training regulation in our industry. We've heard some raw data quoted yesterday. This is all dependent on the number of truck hours and the amount of exposure the employees have, personal injury and property damage. Our people are exposed to this every day and our record is not that bad.

Another commenter from this industry stated (Tr. p. 248):

The PMA [Pacific Maritime Association] conducts forklift training based on ASME B56.1 to provide skilled operators for employers to meet the requirements of § 1917.27(a) and § 1917.97(a)). This program has served the industry well. Also, on-the-job training is a tradition on the waterfront and qualification by experience and training have proved to be effective.

On the other hand, several witnesses at the hearing testified about powered industrial truck accidents that resulted in deaths and serious injuries in the marine cargo-handling industry. They supported OSHA's proposal to improve training for operators in this sector.

For example, one commenter (Tr. p. 437) stated:

One of the port authorities in the U.S. contracted [with] me to conduct training for the stevedoring and the ILA on the east coast.

We conducted a three-day training program and we had a 54 percent failure factor on basic knowledge.

Another hearing participant (Tr. p. 393) reported:

In fact, last year I investigated a death on a stevedoring area where a supervisor was driving a lift truck with no training that ran over an employee on a shipping dock.

It is clear to OSHA that powered industrial truck accidents are a major cause of injuries and deaths in the marine cargo handling industry. An OSHA contractor that studied fatality reports for the period 1991-1993 collected by the National Institute for Occupational Safety and Health for the Census of Fatal Occupational Injuries Program determined the number of fatal and serious injury accidents reported during the period of study (Ex. 38). According to this study the longshoring and marine terminal industries experienced a percentage of powered industrial truck accidents that was 10 times greater then the second highest industry (28.1 percent of all fatal accidents in the maritime industries compared with 2.8 percent in the second-ranked industry). An OSHA study of fatalities in the marine cargo handling industry indicated that 19 of 165 fatalities that occurred between 1975 and 1984 were attributable to the improper operation of powered industrial trucks. (See section IV. A. 4 above.)

Based on this information and other evidence discussed elsewhere in this preamble, OSHA concludes that powered industrial truck accidents are a major cause of serious injuries and deaths in the marine cargo handling industry. OSHA further concludes that the Agency's current training requirements do not sufficiently protect employees in that industry from death and serious injury from powered industrial truck accidents, and that it is necessary to issue these training requirements to protect those employees from a significant risk of injury and death.

There are a number of additional responses to those commenters in all industries who recommended that OSHA retain the present, very general, training requirements. First, the statistics demonstrate a high level of accidents, injuries, and deaths resulting from improper powered industrial truck operation in all industries. (See the discussion at part IV.A. above.) The Agency's existing training requirements have not worked well enough to reduce those injury rates.

However, without the existing requirements, rates would likely have been much higher. The studies demonstrate that trained operators make fewer errors. The FEA points out that a percentage of current operators are trained. Therefore, it is reasonable to conclude that the existing general training requirement has resulted in the training of a percentage of the operators and without this existing training there would be more errors and, therefore, more accidents. The new standard will increase the number of trained operators and the quality of the training, further reducing accidents.

Second, the existing requirement is so general that employers may believe that they have fulfilled their obligation by providing very little effective training. Third, the existing provisions provide very little guidance on what training is necessary and effective. Fourth, as discussed above, studies are available that show that effective training will reduce accidents (Ex. 38). Finally, many commenters told OSHA that their experience demonstrates that better training will reduce fatalities and injuries, and some provided examples of how their training programs (similar to the program required by the final rule) had reduced accidents.

The revised training provisions require the employer to develop a training program based on the general principles of safe truck operation, on the type of vehicle(s) being used in the workplace, the hazards of the workplace created by the use of the vehicle(s), and the general safety requirements of the OSHA standard. OSHA is not specifying the time that must be spent on the training or the exact methods that must be used to train operators. OSHA is, however, requiring that trained operators know how to do the job properly and do it safely, as demonstrated by workplace evaluations at the time of initial and refresher training and at periodic intervals (at least once every three years). This approach gives employers the flexibility to develop training programs appropriate to their workplace and avoids unnecessary specification. Thus, this final standard will be both performance-oriented and effective.

[63 FR 66237, Dec. 1, 1998]


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