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.

June 15, 1999

Mr. Victor F. Kraker, CSP
404 Woodcock Drive
Cranberry Township, Pennsylvania 16066

Dear Mr. Kraker:

Thank you for your May 7, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Office of General Industry Compliance Assistance in the Directorate of Compliance Programs. You have questions regarding the Powered Industrial Truck Operator Training, Final Rule, December 1, 1998 (29 CFR 1910.178(l)). We appreciate the opportunity to provide you with clarification on this matter.

You question what is meant in the standard by different "types" of trucks. You indicate that you utilize many counterbalanced trucks in your operation. The manufacturer and models are quite varied although they all perform the same basic function.

Your specific question is, "Should training, and operator evaluation be conducted for each make and model the employee will operate, or should the training and subsequent operator evaluation be conducted for each "type" of powered industrial truck?"

1910.178(l)(i) states that "The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l)." 1910.178(l)(3) requires that operators receive training in the topics which are applicable to the safe operation of the truck in the employer's workplace.

Therefore, an operator must be trained and evaluated in the safe operation for the type of truck that the operator will be assigned to operate in the employer's workplace. For example, if an operator is assigned to operate a sit-down counterbalanced rider truck, then the operator must be trained and evaluated in the safe operation for that type of truck. If an operator is assigned to operate an operator-up counterbalanced front/side loader truck, or a rough terrain forklift, then the operator must be trained and evaluated in the safe operation for those types of trucks.

A sit-down counterbalanced rider truck, an operator-up counterbalanced front/side loader truck, and a rough terrain forklift are different types of trucks. Operators who have successfully completed training and evaluation as specified in 1910.178(l) (in a specific type of truck) would not need additional training when they are assigned to operate the same type of truck made by a different manufacturer. However, operators would need additional training if the applicable truck-related and workplace-related topics listed in 1910.178(l)(3) are different for that 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 contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,

Richard Fairfax, Director
Directorate of Compliance Programs