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For employers that utilize material handling equipment or powered industrial trucks such as forklifts, reach trucks, swing reach trucks, order pickers, stand-up forklifts, walkie-riders, etc. remaining OSHA compliant with respect to training new operators / drivers and recertifying previously certified operators can be very confusing.

To ensure that you, as the employer, remain compliant with OSHA’s 29 CFR 1910.178 forklift code here are a couple of suggestions:

New Operators:  For each employee that you want to operate equipment they will need to receive formalized training (i.e. classroom, lecture, online, etc.)  While the OSHA code does not specify a written exam be administered, it does require that you be able to verify knowledge.  You would be extremely hard pressed to demonstrate “Operator Knowledge” month’s later if the employee is involved in a serious or fatal accident. 

The trainee must then receive a practical demonstration of each piece of equipment they are receiving training to operate.  This means that the trainees need to see the equipment in operation.  Then, the trainees are to receive formal hands-on training on each piece of equipment they are receiving training to operate.  Finally, trainees shall be evaluated as they operate the equipment to ensure they can properly and safely operate the equipment.

Recertification Every Three Years:  Employers are required to verify the knowledge and skills of every certified equipment operator every three (3) years.  This requirement frequently confuses employers and even most equipment trainers.  The operator’s knowledge and skills must be evaluated every three (3) years.  The code does not require operators undergo a complete retraining unless the operator has been observed operating unsafely, has received an evaluation indicating performance deficiencies, if new equipment is introduced to the workplace or if there has been significant changes to the employee’s workplace. 

As the employer, your responsibility is to verify that the operator has the appropriate knowledge required for safe operation and to visually verify that the operator can properly and safely operate each piece of equipment they are certified to operate.  Operators who are certified to operate other types of equipment must still complete full training for each new piece of equipment they are expected to operate.


So, employers have some flexibility when it comes to the tri-annual recertification.  Most employers have opted to have their operators complete the classroom / formal training again which is followed-up with an evaluation of the operator’s performance and skills operating the equipment.  What’s most important is to be able to verify and document that the operator has retained the knowledge necessary for safe operation. 


At a minimum, you need to administer a written exam for your operators to complete.  This will provide the employer with the documented verification that the operator either has or does not have the necessary knowledge.  If the operator passes the test he / she can move on to complete either a full hands-on re-training or a visual verification of his / her performance skills.  If he / she does not pass the written exam they will need to complete the classroom / formal training again.  If they do not pass the performance evaluation, they will need to complete the hands-on training again.

It is extremely important to get the knowledge and skills evaluations and / or re-training documented for inclusion into the appropriate training / HR files.


So, whether your facility uses sit-down forklifts, stand-up forklifts, order pickers, reach trucks, swing reach trucks, walkie riders or pacers the same training standard applies to all equipment with respect to OSHA’s 29 CFR 191.178 forklift code.


Askthesafetyman.com provides BASIC Knowledge and Skills Evaluation certifications, formal classroom, group and online material handling / powered industrial truck training.  We also provide a complete OSHA compliant forklift training package that can be used for classroom / group training as a presentation or, it can be loaded onto a computer and used as a training on demand system to provide individual operator training on an as needed basis.

Askthesafetyman.com provides local onsite training throughout Southern California.  Based in Temecula, we cover areas from San Diego to Temecula to Riverside to Los Angeles and Orange counties.  Call us for complete information at 1-800-277-2267 or email us at CustomerService@Askthesafetyman.com.