Standard Interpretations - Table of Contents
• Standard Number: 1910.178(l)

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

April 8, 1999

Mr. Jerry M. Gillooly
Safety Director
Bohl Equipment Company
534 Laskey Road
Toledo, Ohio 43612

Dear Mr. Gillooly:

This is in response to your letter of February 17, requesting compliance assistance from the Occupational Safety and Health Administration (OSHA) regarding the revised powered industrial truck operator training standard 29 CFR 1910.178.

Your specific inquiry concerned 1910.178(l)(4)(ii)(D), which requires refresher training in relevant topics when the operator is assigned to drive a different type of truck. Refresher training compliments the initial training required by paragraph 1910.178(l)(3) and serves to reinforce that initial training. The type and amount of training needed in refresher training when the operator is assigned to drive a different type of truck depends on factors such as the different characteristics of the different or new type of truck. For example, an operator who has been trained and evaluated in the use of a sit down counter-balanced rider truck would need refresher training if that operator is assigned to operate an operator-up counter-balanced front/side loader truck or a rough ter