Standard Interpretations - Table of Contents
• Standard Number: 1910.178; 1910.178(l)(4)

This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.

August 1, 2005

Mr. Robert Hearne
1448 SR 333
Russellville, AR 72802

Dear Mr. Hearne:

Thank you for your April 12 letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry Enforcement for an answer to your question regarding OSHA's powered industrial truck standard, 29 CFR 1910.178. Your question has been restated below for clarity.

Background: 29 CFR 1910.178(l)(4)(iii) requires that an evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years.

Question: Would a written exam alone (i.e., without practical operation of the truck) suffice for the evaluation requirement stated above?

Reply: The "evaluation" of "performance" required by the standard cannot be met by a written exam alone. A written exam by itself does not indicate whether the operator is operating the powered industrial truck safely. In most cases, the person conducting the evaluation would do two things: first, observe the powered industrial truck operator during normal operations to determine if the operator is performing safely, and second, ask pertinent questions to ensure that the operator has the knowledge or experience needed to operate a truck safely. In some cases, because of the d