Bringing "Site" to the Blind
Site specific ... site specific ... site specific ...
Repeat those words enough and they change from an OSHA training mandate for lift truck operators to a meaningless mantra. I confess, MHM has pounded those words into your head ever since the need to revise 29 CFR 1910.178 was introduced. It’s become such a buzz phrase that unscrupulous trainers use it to sell their classroom-based programs.
Get this straight: a classroom is not a site.
A site is a warehouse, distribution center, dock or yard. If you rely on an outside trainer to get your operators up to speed on your lift trucks, make sure that trainer understands your environment. That means touring it, observing operations and noting load characteristics.
If a trainer doesn’t do those things and you suffer a lift truck accident, can that trainer be cited by OSHA? No, but you can — and probably will be. Ultimate responsibility for training and evaluation is yours. Still, whether that trainer is internal or external, he should be part of your operator training team.
And don’t lull yourself into a false sense of security by following the revised OSHA reg to the letter. It’s the spirit that counts. It’s the spirit that makes you safe.
It’s one thing to understand what makes a load go up and down. Understanding the internal workings of an industry is another. Jim Shephard, president of Shephard’s Industrial Training Inc., sees the surface approach to the Powered Industrial Truck Operator Training (PITOT) standard all the time out in the field. His firm does PITOT. He also makes potential customers walk the walk of site-specific training — by walking their sites. He told me about one client who was high on training but blind to what was going on in his environment.
"They met OSHA’s minimum requirements," he said. "But I documented 21 pages of needed improvements to make their plant function better. These were material handling problems that if you didn’t look for them, you wouldn’t see."
Another "law-abiding" client had a dock problem that required a rather simple fix. Although his lift trucks were running fine, he forgot about the over-the-road trucks visiting his docks every day. The condition of the trailers attached to the trucks runs the gamut — therefore, so do the operating environments for lift truck operators driving in and out of them. What did this company use to stabilize and standardize these environments?
Dock locks with one wheel chock. Shephard suggested using two chocks with each dock lock so that even if the device didn’t fully engage the trailer it would still be secured. Premature trailer departure is one of the more common causes of lift truck accidents. That’s why understanding load behavior should be part of every PITOT course.
"Many companies routinely roll 25,000 pounds on and off 18 wheelers at the dock, including lift truck, attachment and product," Shephard told me. "You can overload that trailer with three palletized loads, resulting in a landing gear collapse."
Accidents like that are OSHA magnets. And inspectors are good at restoring vision to managers who were blind to other violations, as well. Open your eyes. Walk your site. Find the pitfalls before your lift truck operators fall into them. Then make them part of your site-specific training.
There I go again.