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OSHA 1915.120

Powered industrial truck training

Subpart G

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.120 and 1910.178(l), who must receive powered industrial truck (PIT) operator training?

Every employee who operates a powered industrial truck must be trained and evaluated before being allowed to operate one unsupervised. See 1915.120 (shipyard rule identical to 1910.178(l)).

  • Employers must ensure operators are competent through training and evaluation before independent operation. 1910.178(l).

Under 1915.120 and 1910.178(l), what topics must PIT operator training cover?

PIT operator training must cover both general and truck-specific topics such as controls, safe operating practices, load capacities, stability, refueling/battery charging, inspection procedures, and workplace hazards. This includes classroom instruction, practical training, and evaluation of performance. See 1910.178(l).

  • Training must include vehicle-related topics (e.g., controls, instruments, capacity) and workplace-related topics (e.g., surface conditions, pedestrian traffic, hazardous locations).
  • Practical demonstration of skills on the actual truck type(s) used is required per 1910.178(l).

Under 1915.120 and 1910.178(l), is hands-on practice required as part of PIT operator training?

Yes — hands-on (practical) training on the specific truck type and attachment is required along with formal instruction and evaluation. See 1910.178(l).

  • Practical training should allow the trainee to demonstrate safe operation under typical workplace conditions before evaluation.

Under 1915.120 and 1910.178(l), who can deliver PIT operator training and evaluations?

An employer may use a qualified person from inside or outside the company to provide training and conduct evaluations, but that person must be competent to train and evaluate operators. See 1910.178(l).

  • The standard does not require a specific certification for trainers, but trainers/evaluators must demonstrate they are capable of teaching and assessing PIT skills and knowledge.

Under 1915.120 and 1910.178(l), when must refresher training and re-evaluation be provided to PIT operators?

Refresher training and/or re-evaluation must be provided whenever an operator is observed operating unsafely, is involved in an accident or near-miss, when there are changes in the workplace that affect safe operation, or when the operator is assigned a different type of truck. Additionally, operators must be evaluated at least once every three years. See 1910.178(l).

  • These triggers are mandatory to ensure ongoing competence and safety.

Under 1915.120 and 1910.178(l), how often must employers evaluate PIT operators?

Employers must evaluate each PIT operator at least once every three years. See 1910.178(l).

  • More frequent evaluations are required if unsafe operation, accidents, or workplace changes occur.

Under 1915.120 and 1910.178(l), what must be included in the employer's operator training certification/record?

The employer must certify that each operator has been trained and evaluated; records should identify the operator, the dates of training and evaluation, and the identity of the person(s) who conducted the training/evaluation. See 1910.178(l).

  • Maintain documentation that shows compliance with training and evaluation requirements.

Under 1915.120 and 1910.178(l), does PIT training need to be specific to the type of truck and attachments used?

Yes — training must be specific to the make and model of the truck and any attachments the operator will use, because operating characteristics and hazards can differ. See 1910.178(l).

  • If an operator moves to a different truck type or uses a new attachment, additional training and evaluation are required.

Under 1915.120 and 1910.178(l), must employers restrict untrained employees from operating PITs?

Yes — employers must not permit an employee to operate a powered industrial truck unless that employee has been trained and evaluated and found competent to operate it safely. See 1910.178(l).

  • Employers are responsible for ensuring only authorized and trained operators use PITs.

Under 1915.120 and 1910.178(l), should PIT training include instruction about workplace hazards like ramps, unstable surfaces, and pedestrian traffic?

Yes — employer-provided training must include workplace-related topics such as surface conditions, ramps, load stability, traffic patterns, and pedestrian interactions to ensure safe operation in the actual work environment. See 1910.178(l).

  • Training must prepare operators to recognize and respond to workplace-specific hazards.

Under 1915.120 and 1910.178(l), does PIT training need to cover safe refueling and battery charging procedures?

Yes — instruction on refueling, battery charging, handling of fuels, and the hazards related to these activities is required as part of PIT operator training. See 1910.178(l).

  • Practical procedures for safe refueling and battery maintenance should be taught and demonstrated.

Under 1915.120 and 1910.178(l), are employers required to train pedestrians or other employees about PIT hazards?

While the standard focuses on operator training, employers must ensure overall workplace safety, which includes informing affected employees about PIT hazards in their work areas and procedures to avoid them. See 1910.178(l) and general employer duty under 1910.

  • Practical steps include marking travel aisles, posting signs, and training non-operators to stay clear of operating PITs.

Under 1915.120 and 1910.178(l), what should employers do if an operator is involved in a PIT accident?

Employers must re-evaluate and provide retraining to the operator after an accident or near-miss before allowing unsupervised operation again. See 1910.178(l).

  • Investigate the incident to identify training or procedural gaps and document any additional training provided.

Under 1915.120 and 1910.178(l), does retraining become necessary when workplace conditions change (e.g., new layout, surface changes)?

Yes — retraining and possible re-evaluation are required when workplace changes affect safe operation, such as modifications to traffic patterns, floor surfaces, or storage configurations. See 1910.178(l).

  • Employers should assess whether the change creates new hazards that warrant additional training.

Under 1915.120 and 1910.178(l), are simulated or classroom-only courses acceptable in place of practical training?

No — classroom or simulated instruction alone is not sufficient; practical, hands-on training on the actual truck type(s) and workplace conditions is required in addition to formal instruction. See 1910.178(l).

  • A combination of formal classroom, practical training, and an evaluation is the OSHA-required approach.

Under 1915.120 and 1910.178(l), can temporary or new hires operate PITs before completing training if supervised closely?

No — employers must not permit unsupervised operation until training and evaluation are complete; however, supervised hands-on training may occur under direct supervision of a qualified trainer as part of the training program. See 1910.178(l).

  • Supervised practice is part of training, but independent operation requires successful evaluation and certification.

Under 1915.120 and 1910.178(l), what records should employers retain to show compliance with PIT training requirements?

Employers should keep certification records that identify the operator, the dates of training and evaluation, and the identity of the trainer/evaluator; these records demonstrate compliance. See 1910.178(l).

  • Records should be retained in accordance with the employer's recordkeeping practices and be available for inspection if needed.

Under 1915.120 and 1910.178(l), does training need to address the limits of truck load capacity and stability?

Yes — training must teach operators how to determine load capacities, the effect of load center and attachments on stability, and safe loading/unloading practices. See 1910.178(l).

  • Practical exercises should include handling loads near rated capacity and recognizing unstable conditions.

Under 1915.120 and 1910.178(l), what responsibilities do employers have to ensure PIT operators remain competent over time?

Employers must provide initial training, conduct regular evaluations (at least every three years), retrain after incidents or workplace changes, and maintain training records to ensure ongoing operator competence. See 1910.178(l).

  • Employers should monitor operator performance and provide refresher training whenever needed to maintain safe operation.