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.

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.

 


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 terrain forklift truck because of the different characteristics of the two trucks. Conversely, operators would not require refresher training when they are assigned to operate the same type of truck with a different manufacturer unless the truck has different characteristics.

Please be advised that 1910.178(l) provides a performance-oriented and cost-effective approach to refresher training. When operators have been trained, evaluated, and certified by the employer as required by 1910.178(l) in the use of different types of trucks, they would not require refresher training simply because they are assigned to operate one of those trucks.

Thank you for your interest in occupational safety and health. If you have any further questions please contact [the Office of General Industry Enforcement at (202) 693-1850].

Sincerely,

Richard Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 1/10/2005]