2.2 Trained, evaluated, and examined daily
Powered industrial trucks are one of the standards OSHA cites most often, year after year, and the citations are overwhelmingly about two things: people operating trucks who were never properly trained and evaluated, and trucks that were never examined before they went to work. Neither one is exotic. Both are paperwork attached to a habit.
1 What "trained" means in 1910.178(l)
The rule is a system, not a class. 1910.178(l)(1)(i): the employer must ensure each operator is competent to operate a truck safely, as demonstrated by successful completion of the training and evaluation in paragraph (l). (l)(1)(ii): that has to happen before the employee operates a truck, except for training purposes.
(l)(2)(ii) defines the three ingredients: formal instruction (lecture, discussion, interactive computer learning, video, written material), practical training (demonstrations by the trainer and exercises by the trainee), and evaluation of the operator's performance in the workplace. All three. A course — including this one — can only ever be the first ingredient.
2 The topic list is not a suggestion
1910.178(l)(3) lists what initial training must cover, and an employer may leave out only topics it can demonstrate do not apply to safe operation of that truck in that workplace. It splits in two.
| Truck-related — (l)(3)(i) | Workplace-related — (l)(3)(ii) |
|---|---|
| Operating instructions, warnings and precautions for the types of truck to be operated (A) | Surface conditions where the vehicle will be operated (A) |
| Differences between the truck and an automobile (B) | Composition of loads and load stability (B) |
| Controls and instrumentation: where, what, how (C); engine or motor operation (D) | Load manipulation, stacking and unstacking (C) |
| Steering and maneuvering (E); visibility, including restrictions due to loading (F) | Pedestrian traffic in areas of operation (D) |
| Fork and attachment adaptation, operation and use limitations (G); vehicle capacity (H) | Narrow aisles and other restricted places (E) |
| Vehicle inspection and maintenance the operator will perform (J) | Hazardous (classified) locations (F); ramps and sloped surfaces (G) |
| Refueling and/or charging and recharging of batteries (K); operating limitations (L) | Closed environments where poor ventilation or maintenance could build up carbon monoxide or diesel exhaust (H) |
Two entries deserve attention because they are usually skipped. (l)(3)(i)(M) pulls in any other instructions, warnings or precautions listed in the operator's manual for that type of truck — so the manual is part of the required content. And (l)(3)(iii) requires training on the requirements of the section itself: operators are supposed to know the rules, not just the machine.
3 Refresher, re-evaluation, and the three-year clock
(l)(4)(ii) lists five triggers for refresher training in the relevant topics: the operator has been observed operating unsafely (A); has been involved in an accident or a near-miss (B); received an evaluation showing they are not operating safely (C); is assigned to a different type of truck (D); or a condition in the workplace changes in a way that could affect safe operation (E).
Then (l)(4)(iii): an evaluation of each operator's performance must be conducted at least once every three years. Note what that is and is not. It is not an expiring licence, and there is no such thing as an OSHA forklift card. It is a workplace evaluation of the person operating the machine, on the machine, done by someone qualified to judge it.
(l)(6) is the record: the employer must certify that each operator has been trained and evaluated, and the certification must include the operator's name, the date of the training, the date of the evaluation and the identity of the person(s) who did them. Four fields. That is the whole documentary requirement, and it is the one that gets cited.
4 The daily examination
1910.178(q)(7) is one sentence with a lot of teeth: industrial trucks must be examined before being placed in service, and must not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination must be made at least daily — and where trucks are used on a round-the-clock basis, after each shift. Defects, when found, must be immediately reported and corrected.
Paired with it, 1910.178(p)(1): if at any time a truck is found to be in need of repair, defective, or in any way unsafe, it must be taken out of service until it has been restored to safe operating condition. There is no "finish this pallet first" in either paragraph.
What the examination covers is set by the truck and its manual, and a workable sheet runs: forks and heels, mast and chains, hoses and leaks, tires, horn, lights, brakes and parking brake, steering, seat and restraint, overhead guard, load backrest, data plate legibility, battery or fuel system, and warning devices. Our forklift daily inspection form prints a blank sheet built from these paragraphs.
5 Maintenance rules people trip over
Paragraph (q) is a maintenance section, and four of its items shape everyday behavior in a warehouse:
- 1(q)(1) — a truck not in safe operating condition is removed from service, and all repairs are made by authorized personnel. Not by whoever has a wrench.
- 2(q)(4) — trucks needing electrical system repairs must have the battery disconnected first.
- 3(q)(6) — no alterations that change the relative positions of parts, no extra parts the manufacturer did not provide, no removing parts, and no additional counterweighting unless the truck manufacturer approves it.
- 4(q)(9) — when any part of a truck exceeds its normal operating temperature and creates a hazardous condition, the vehicle comes out of service until the cause is eliminated.
The counterweight rule in (q)(6) is worth saying out loud, because adding weight to the back looks like the obvious fix for a load that will not lift. It changes the load-moment balance the whole machine was designed around, and it does it without changing the data plate.
6 Construction is the same, general industry is not the ceiling
If your company works both sides, the training rule travels: 1926.602(d) states that the requirements applicable to construction work are identical to those in 1910.178(l). The equipment requirements are not identical — 1926.602(c) has its own list, including the personnel platform rule at (c)(1)(viii) that general industry lacks — but nobody gets a lighter training obligation by moving to a construction site.
One more thing worth knowing about the standard's own limits: 1910.178 does not cover compressed air or nonflammable compressed gas trucks, farm vehicles, or vehicles intended primarily for earth moving or over-the-road hauling — 1910.178(a)(1). A telehandler on a construction site is handled under 1926.602; a yard tractor moving trailers is not a forklift.
- Training under 1910.178(l) is formal instruction + practical training + a workplace evaluation. All three, before solo operation.
- Trainers and evaluators must have the knowledge, training and experience to do it — (l)(2)(iii).
- Refresher triggers include an accident or near-miss, unsafe operation, a different type of truck, or a workplace change.
- An evaluation of each operator is required at least once every three years — (l)(4)(iii). There is no OSHA forklift card.
- (l)(6) certification records four things: operator name, training date, evaluation date, who did them.
- (q)(7): examine before placing in service, at least daily — after each shift on round-the-clock operations. Defects park the truck.
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.