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How OSHA Has Changed (or not changed)
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The toughest requirement for businesses to comply with concerns operator re-certification. |
Of course, one could argue that the previous wording said all that needed to be said: “Only trained and authorized operators shall be permitted to operate a powered industrial truck.” No problem there! It was the rest of it that was the problem. Anybody remember what the rest of it said? Say it with me now...“Methods shall be devised to train operators in the safe operation of powered industrial trucks.” Methods shall be devised? Could it be any more gray?
With the current PITOT standard, trainers and employers can now be confident that the training delivered is sufficient by covering all of the required items in the standard which mandates a detailed criteria including evaluated demonstration performed by the operator. Gone are the days of waiting for an accident investigation to reveal the adequacy (or inadequacy) of the “methods devised” for forklift operator training.
Trainer
Qualifications
One of the more contentious issues within the standard is
that of the qualifications of the trainer. The standard states that
the instructor of PIT operators shall have the “knowledge, training
and experience to train powered industrial truck operators and evaluate
their competence.” This wording addresses the importance of what
the operator is being taught as well as who is teaching it. And well
it should. In the past, it was impossible not to have sat through training
sessions conducted by trainers who: a) had great communication skills
but no real knowledge of what they were talking about; or b) had great
knowledge of the subject but not a clue as to how to convey it; or c)
had an inability to deal with anyone who didn't “get it.”
By injecting an expected level of competence on the part of the trainer into the standard, OSHA has effectively raised the training bar. Having the most experienced operator deliver the training based solely on operational experience simply doesn't cut it any more, nor does plunking the operator(s) down in front of a computer monitor to sit through an interactive CD ROM. Certainly, there is no denying that the experience of an operator or a good CD ROM can add value to a training class when used properly by a competent trainer; but on their own, they can be woefully inadequate. As for those who would argue that computers do not have “off” days like humans do, well, those people should try spending some time with my computer!
Site
and Equipment-Specific Training
Perhaps
the most difficult aspect of the standard for business and industry
to wrap their collective minds around has been the requirements regarding
site and equipment-specific forklift operator training. This requirement
has put a serious crimp in the style of how many employers previously
handled their training, which was usually off-site. Unless an outsourced
training provider could accurately reproduce the same conditions found
in the employee's workplace (load, terrain, grade, storage and stacking
of product, operating environment, etc.), the training performed would
not meet the standard. Then there are the specific issues concerning
the forklift: type classification, attachments, fueling/charging, etc.
Even if the off-site trainer somehow managed to get around these obstacles,
there's just no getting around the requirement for an evaluation of
the operator's competence “at the work site.”
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Having the most experienced operator deliver training based solely on operational experience simply doesn't cut it any more. |
Reputable outside training providers must make themselves familiar with the operating conditions and equipment at the site as well as any in-house policies and/or operating procedures before proceeding with any training. Then they must insert this information into the class and ensure that everyone involved understands it. This is no small task! Many employers choose the option of having one or several of their own people trained as instructors and then having them conduct the in-house operator training. This effectively addresses the issues involved with providing site and equipment specific training because the employee who conducts the training on behalf of the employer may possess a level of familiarity and understanding with the machinery and working conditions that no outside trainer could match. It also addresses the issue of the trainer's competence, which is significant in light of the OSHA PITOT standard and therefore significant to employers.
Retraining
and Recertification
Probably
the toughest requirement for business and industry to comply with concerns
operator re-certification. There are a lot of employers out there who
are, to say the least, unhappy about having to formally train, evaluate
and certify all of their PIT operators. In the same vein, they can become
absolutely rabid when they learn that they also have to re-evaluate
them at least every three years! Re-evaluation or testing was never
required on a regular basis before the standard was promulgated, and
you can see why large employers may have a problem with this. It is
conceivable some enormous outfit may spend huge gobs of time in ensuring
that all of the operators get the required training, only to emerge
from the task to find that they must now turn around and re-evaluate
those same operators!
In the past, re-training and/or evaluation were only done in the event of an accident and even then only in some cases. Now operator's ability must be tested every three years, minimum, and even more often if the operator is involved in an accident or near-miss incident attributable to operator error. A bright spot regarding the re-evaluation requirement from industry's perspective is that it can be done on the job, so production does not necessarily need to be disrupted. However, even though the OSHA training standard only mandates a re-evaluation of the operator's competence in operating the machine, it is also prudent to re-evaluate their theory knowledge with a short theory test as well, just to cover all the bases.
Results
Are In
In summation
then, to be able to assess how the regulations have affected the forklift
industry, one must look at a snapshot of the industry before and after
the regulation.
Before the regulation, employers and trainers found it difficult to provide adequate PIT operator training, as there was no definition given by OSHA on the subject. In addition, no direction was provided regarding site and equipment-specific issues or the competence of the trainer. The requirement for operator re-evaluation was non-existent which gave rise to accidents and incidents arising out of ignorance and complacency.
All of these factors combined to form an industrial culture of little or no training. If training was taking place, it was generally cursory or inadequate and delivered by someone with no ability for the type of work at hand.
After the regulation, we have a PITOT standard that is reasonably clear and very comprehensive. There is still a bit of the negligent industrial culture out there that will fight every change tooth and nail simply because they can. The level of awareness that this standard has brought to business and the industry across America regarding forklift safety and operator training has caused the most significant effect of all...fewer people are dying. It's working.
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