Complying with OSHA’s Training Standard
More specifically, that’s 29 CFR 1910.178, Powered Industrial Truck Operator Training (PITOT) standard. Basically, PITOT spells out how, when and where your powered industrial truck operators must be trained.
PITOT went into effect December 1, 1999, so compliance is still in its infancy. All new OSHA regulations need time for interpretation and dissemination — as well as incorporation into the compliance rhythm. That’s happening.
“I know that there are a few companies that OSHA inspectors are looking at real hard,” says Jim Shephard, president of Shephard’s Industrial Training Systems Inc. At this point, observes Shephard, OSHA’s hard looks are reserved for cases involving a fatality or a serious accident.
However, a fatality or serious accident needn’t involve a lift truck or other powered industrial equipment to trigger an OSHA inspector’s questions about PITOT compliance.
“In practically every instance where I’m involved in an investigation, they ask for operator training documentation as part of their routine,” says Earl M. “Chip” Jones, attorney at law for the firm of Littler Mendelson. The investigation may be triggered by an accident involving, say, lockout/tagout, but the inspectors still want to know about industrial truck training. “They want to see that program when they walk in the door,” Jones says.
One OSHA inspector told me, “We’re enforcing that standard like any other. When we inspect the facility, that’s one thing we check for, operator competency.” The Powered Industrial Truck Operator Training standard has been added to the list of documents an inspector inquires about in any routine investigation.
The important factor in operator training is the existence of the standard, the inspector contends. “We have cited the standard more,” he says. “We have criteria now. Before it was just ‘You will have training.’ Now the employer has to certify somebody to do the training. You can’t even hire an experienced operator without first checking him out on the standard’s requirements.”
The question is, how far into the PITOT regulation does an OSHA inspector take his investigation? When the accident or fatality does not involve a powered industrial truck, the inspector is not likely to go behind the training documents and interview the employees, Chip Jones recalls.
Jim Shephard worries whether all training programs comply with PITOT’s requirements: Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, videotape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee) and evaluation of the operator’s performance in the workplace.
“I think there is an interpretation of the regulation that a lot of people have missed,” Shephard says. “Companies have been sold on the videotape and the one-hour session; they feel that the program they bought meets the OSHA requirements. These programs fall short, but their sponsors don’t tell the company.”
Small companies often rely on local OSHA inspectors to check out training services.
“Some company with two or three lift trucks and an operator who has been on the job for 15 years will be told that the employer has to buy a video for $150 in order to comply with the standard,” says the inspector. “There’s a lot of that going on.”
Sometimes an employer falls for the pitch. According to the inspector, “They buy the video, put it on the shelf and think they’re in compliance. We’ll come in and they say, ‘Here’s my video.’ And it’s still in the wrapper.”
Same with compliance with PITOT: It’s still in the wrapper. But your company is in trouble if the inspectors have to unwrap the standard for a violation.