The OSHA rules state: "Prior to operating a truck in workplace, the EMPLOYER must evaluate the operators performance and determine the operator to be competent to operate a powered industrial truck safely"
OSHA and Temporary Employees OSHA has issued several letters of interpretation on the subject of training of temporary employees.
1. There could be a shared responsibility for assuring operators are adequately trained.
2. The responsibility for training should be spelled out in contractual agreement between the two parties.
3. The temporary agency may conduct initial general training and evaluation certification.
4. However, the host employer must provide site-specific information and training on the use of the particular types of lift trucks and workplace-related topics that are present in the workplace.
Key Point The Hands On Evaluation is, arguably, a second layer of protection enabling the host employer and the temporary agency a secondary physical means of determining if the candidate has the necessary knowledge, training and experience to operate a forklift safely in the workplace. It becomes apparent quickly during the Hands On Evaluation whether the candidate has actually operated a forklift before. Hf the candidate fails this portion of the evaluation they should not be placed into service until an adequate training program has been completed.
It's really quite simple. It only makes sense to perform some kind of evaluation of the candidate in the workplace. Would you really let a person operate a forklift just because they wave their hand and say "I can operate a forklift" without ensuring that they actually have some experience. Of course. you wouldn't.
OSHA likes documentation.
2 steps to OSHA forklift safety compliance:
1. The EMPLOYER must certify(document) that the operator has received THE training as described in the standard covering forklift operations. The ropics are specific and simple.
2. The EMPLOYER must provide proof (document) that the operator has had a hands on evaluation that is site-specific and equipment-specific.
Who can conduct the Hands On Evaluation?
OSHA made this part easy - Training and evaluation must performed by a person with knowledge, training and experience to train powered industrial truck operators and evaluate their competence. This means that any reasonably experienced operator ban become the Designated Evaluator for the host employer. Usually, the most experienced person, a supervisor, manager, or shift leader, as long as they meet the above criteria.
General requirements for training and evaluation:
- Formal (lecture, video, interactive computer, etc) training
- Practical training using demonstrations and exercises
- Employers must certify that each operator has received the training
- Employers must evaluate each operator's performance at lest once every 3 years
Your client's responsibility is clear. Formal safety training and evaluation must be accompanied by a Hands On evaluation to be in full compliance. The staffing agency may conduct formal training. The employer is responsible for the Hands On evaluation and certification. There are programs available to achieve these objectives in an easy to use, and complete format. Visit The Material Handling Dealers Organization - www.mheda.org or www.osha.gov for more information.