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.

July 23, 2003

Mr. Robert R. Brant
OSHA Coordination
United States Postal Service
475 L'Enfant Plaza SW
Washington, DC 20260

Dear Mr. Brant:

Thank you for your April 24 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Your letter has been referred to (DEP's) Office of General Industry Enforcement for an answer to your questions regarding powered industrial truck operator trainer qualifications. Your scenario and question has been restated below for clarity.

Background: 29 CFR 1910.178(l)(2)(iii) states: All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.

Scenario: Driver instructor examiners are training some powered industrial truck (PIT) operators. The driver instructor examiners have been certified to teach PIT operator training, however they do not operate PITs on a regular basis or as part of their job function and responsibility.

Question: What does OSHA mean by the word "experience" in 29 CFR 1910.178(l)(2)(iii)? Specifically, does it mean that the trainers must be certified to train drivers to operate PITs, or does it mean that the trainers must operate PITs on a regular basis as part of their job function and responsibility?

Reply: A trainer must have the "knowledge, training, and experience" to train others how to safely operate the powered industrial truck in the employer's workplace. In general, the trainer will only have sufficient "experience" if he has the practical skills and judgment to be able to himself operate the equipment safely under the conditions prevailing in the employer's workplace. For example, if the employer uses certain truck attachments and the trainer has never operated a truck with those attachments, the trainer would not have the experience necessary to train and evaluate others adequately on the safe use of those attachments. However, the standard does not require that the trainers operate a PIT regularly (i.e., outside of their operator training duties) as part of their job function or responsibility.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,


Richard E. Fairfax, Director
Directorate of Enforcement Programs