Forklift Safety: How Effective is your Lift Truck Safety Program?

Effective December 1999 all operators of industrial lift trucks were required to be trained and evaluated in accordance with the new OSHA ruling. Why did OSHA revise the requirements? Well the long story would detail years and years of studies on injuries and deaths resulting from industrial truck accidents, probable causes, possible prevention, statistics, statistics and even more statistics. An enormous amount of time and money was spent on this initiative. The short answer is "It needed to be done". The old ruling stated simply that "Only trained and authorized operators shall be permitted to operate a powered industrial truck. methods should be devised to train operators in the safe operation of powered industrial trucks." This ruling was far too vague in allowing companies to determine what adequate training was.

My Experience

My first experience driving a lift truck goes back almost 20 years. I had recently started working for this unnamed company and the guy than normally drives the forklift wasn't in so I hopped on the forklift and started playing with the controls to see what they did. A few minutes later I was moving product around the warehouse. A couple of months later the plant manager called me into his office and told me he needed to make sure that all the warehouse guys were certified to drive the forklift. He then said "I've seen you driving around the warehouse, you know how to drive the forklift, right", I answered "yeah". He signed a certification card, handed it to me and said, "you're certified". My experience was far from unique and even though common sense would say otherwise, my employer was arguably in compliance with the current OSHA standard.

Over the years I have been involved with in-house, outsourced, and prepackaged training and certification programs. What most of the programs had in common was minimal and very generic instruction, a very simple written test, and a quick driving test on usually a single forklift. The programs seemed to be more of a formality of going through the motions to provide documentation to support compliance in case "OSHA ever showed up" instead of being a safety initiative. This is how a lot of safety and compliance programs are conducted in businesses. Most companies put these programs in place with the best of intentions and never realize the shortcomings of the training until there is a serious accident.

The OSHA Rule

When I first sat down to read OSHA's Powered Industrial Truck Training; Final Rule, I'll admit I did not dive into the 60 plus page report with great enthusiasm. I was expecting to see a bunch of ridiculous bureaucratic requirements which would make our jobs more difficult and probably do very little for safety. What I found was a document which outlined legitimate safety concerns and provided detailed descriptions of areas which should be part of any operator training program. I was way impressed. In fact OSHA has gone beyond creating the legal document of the rule and has provided information in the form of course outlines, sample documents, and even a comprehensive PowerPoint® presentation. All of these materials are available at OSHA's Lift Truck Training and Reference Materials web page. I also suggest reading and incorporating the report on forklift fatalities into your training program, it is certainly an attention-getter. While the OSHA supplied materials alone do not make a complete training program, they certainly provide the foundation for one.

I'm purposely not going to detail the entire OSHA ruling since I feel it is important for those implementing safety programs to read the actual OSHA material. What I will do is go through some of the training options available, highlights of the OSHA Rule, and some additional suggestions for your safety program.

The most significant changes in the OSHA ruling involve the training content and methods. OSHA requires the training to be a combination of formal instruction and practical training which emphasizes the specific types of trucks and the specific operating environment the employee will be working in. And, that after the training is complete the employer must evaluate the the trainee's knowledge and skills and determine that the employee is competent to operate the truck safely. OSHA leaves the specific method of formal instruction open. The consensus of the industry is that the formal training should be some type of classroom training consisting of comprehensive training manuals supplied to the trainees along with verbal instruction detailing the content of the training materials. Videos, slide shows, and overhead transparencies may be used to add redundancy to the training materials. Expect the formal classroom training to last at least 3 hours, make sure you allow time for discussions. While the method for formal training is flexible under the OSHA ruling, the content is not. OSHA is very specific on topics which must be covered, again I refer you back to the OSHA reference materials.

Practical Training

Practical training may prove to be more difficult for employers, especially if you are training first time operators. The ruling states that practical training be conducted "under the direct supervision of persons who have the knowledge, training, and experience to train operators and evaluate their competence; and where such operation does not endanger the trainee or other employees". Which means that until an operator has been evaluated and determined to be competent to operate the truck safely, that employee can only operate the truck under the "direct supervision" of the trainer. With experienced operators this should not pose a problem since the practical training and evaluation will generally go quickly, however, inexperienced operators may require a significant amount of time under the direct supervision of the trainer before they are determined to be "competent". If you have an operation which uses several different types of vehicles and/or has varied driver responsibilities, you may find it more effective to train and authorize the operator on only one vehicle and for only specific tasks initially, giving the operator time to acclimate prior to moving on. An example would be to only authorize an operator on the sit-down forklift moving and stacking product in a bulk storage area. After the operator has gained sufficient experience in this area you can then train and authorize the employee to work in a racked area, on the dock loading and unloading trailers, or on other types of vehicles.

Operator Evaluation.

The method of operator evaluation is also left open by OSHA. The industry standard is generally a written test and a performance test on the specific vehicles the operator will be operating. Creating an effective written test requires a balance between getting enough procedural and technical questions to ensure the employees knowledge, while remaining within the level of literacy of your operators. Operators may have difficulty with the written test even though they know the material due to language issues as well as literacy levels. Giving the written test verbally will often resolve these issues. OSHA does not dictate that a written test is given nor do they dictate a specific Pass level, however, I believe that a written test is the best means to ensure an operators knowledge of the course content. Historically these written tests have been very simple in order to avoid the situation created when operators FAIL. I suggest making the tests comprehensive (within reason) and plan retraining and retesting of those who may fail. The retraining would simply be going over the questions answered incorrectly until you are sure the operator now understands, and then retesting. Remember, the purpose is to ensure the operators have the knowledge; a comprehensive test with a plan for supplemental training and testing will prove to be more effective than the standard "you have to be an idiot to fail this" test. Also note that "comprehensive" doesn't have to mean "difficult." The test should be fairly easy to pass, it just shouldn't be a "no-brainer."

Performance Test.

The performance test should require the operator to demonstrate knowledge of all controls and safety equipment on the vehicle as well as demonstrate the actual tasks in the workplace the operator will be required to perform. If the operator will be placing pallets in pallet racking, loading trailers, and hand stacking product with a man up truck, the operator should be tested in all of these operations. The operator should be tested on each piece of equipment he/she will be using. If your operators sometimes use attachments on the truck they should be instructed and tested on their proper use as well.

Training Options.

There are many training options available and it is important to investigate each option to ensure that your operators are getting a comprehensive training program.

Prepackaged training kits.

It is impossible for a prepackaged training program alone to provide all of the information necessary for your operation. Remember you must train on the specific equipment and operating conditions of your operation. Prepackaged kits usually contain training booklets, test materials, videos, transparencies, or computer software. The prepackaged kit can prove to be an effective component of an in-house training program if supplemented with site-specific, equipment-specific training materials and conducted by persons with the knowledge and skills to conduct the training. Check my Links page for vendors of safety training materials.

Outsourced training.

Outsourced training has become very popular with companies. Outsourced training has the advantage of a trainer who is usually more knowledgeable in lift truck safety and operation than anyone you may have in house. The problems with outsourced training is that they are usually a generic training program and will not be addressing the specific hazards of your operation. If the training occurs off site with a group of operators from different companies it will be impossible for the trainer to be giving enough site specific and equipment specific training to meet each companies requirements. If you use off-site training you should supplement it with site-specific, equipment-specific training in house. If you use outsourced training which conducts the training in house make sure the trainer reviews your operation and incorporates your operational issues into the training program. Another problem with outsourced training is that companies mistakenly feel that since they outsourced the training that they now have safe operators, and very little is done in-house to ensure that the operators are performing as trained. Outsourced training is usually available from your lift truck equipment dealer as well as consultants.

In-house training.

In-house training is likely the best way to ensure that site-specific hazards are being adequately addressed. If you have resources in house with the knowledge and skill to provide this training, this is probably the option for you. If you do not have personnel in house with this knowledge you will have to outsource the training. Many outsourced training programs also provide "train the trainer" courses which help to prepare in-house personnel to conduct the training. The OSHA supplied materials are very helpful (and free) in putting together your in-house training program. You may also want to incorporate some of the prepackaged training materials and use training materials from the manufacturer of the vehicle.

Additional Comments

Any safety program must start with an evaluation of the types of equipment and operation in which the equipment will be used. Site-specific hazards should be identified including, inclines, overhead obstructions, uneven or slippery surfaces, blind corners, etc. This evaluation provides a good opportunity to look for ways to eliminate hazards rather than training operators to deal with them. Document all equipment which will be used by the operators, this includes lift trucks, dock levelers, attachments, charging and battery changing equipment. Most equipment will have safety information provided with the equipment, if you do not have this information contact the dealer or manufacturer to obtain it. This information should be incorporated into your training materials.
Follow-up supervision is often a neglected part of lift truck safety programs. Operators frequently pass the safety training and immediately start operating a lift truck in an unsafe manner. It is imperative that you have supervisors that have gone through the safety training (even if they will not be operating the trucks) to ensure that they have the knowledge to enforce the safe operation of the equipment. It must be made clear to the supervisors that they are responsible for ensuring that operators are operating in a safe manner. Any observed violation of safety procedures must be addressed immediately, failure to do this will guarantee an unsafe operation. Would you feel safe driving in your car if there was no enforcement of traffic laws? If you've ever driven in a city in a third-world country you would know what it's like. Remember that training and testing ensures the operators know how to operate safely but proper supervision will ensure that they do what they know. I firmly believe that follow-up supervision after the training program is as important — if not more important — than the safety training itself.
OSHA requires refresher training if an operator is observed driving in an unsafe manner, has been involved in an accident or near-miss, or if different equipment or hazards are introduced to the workplace. OSHA also requires that operator's performance be evaluated every three years. OSHA does not require that the operator goes through the entire training program every three years, only that their performance be evaluated. I would suggest that they you do conduct the entire course at least every three years anyway. OSHA also allows you to accept previous training an operator has had with a previous employer provided it meets the requirements of your training program. Since the content of the previous training is almost impossible to determine I recommend sending all new employees, regardless of previous training, through the complete training program.
Dock Safety is often overlooked or underemphasized in training programs. In my opinion, the loading dock is usually the most dangerous area of a warehouse for lift truck operators as well as non operators. Training should include proper use of dock levelers, truck restraining devices, trailer inspection, and any additional signaling or safety devices used. See article on Dock Safety.
Limit the use of vehicles and the area in which they can operate. If someone will not be using a piece of equipment regularly, do not authorize them to use it. Try to refrain from "I want them to be authorized just in case". Taking someone who does not drive a lift truck on a regular basis and allowing them to hop on the truck once or twice a year is an accident waiting to happen. If you have people you need as backup, try to schedule them to get some time on the vehicle periodically to keep their skills up. I am not against training these people in lift truck safety, in fact having non-operators who work in warehouse and dock areas in the classroom training is a great idea, I just think it is dangerous to have inexperienced operators. Do not underestimate how much an operators level of experience affects safety. Also, I suggest not allowing lift trucks to operate where they are not needed. A lift truck is not a means of transportation, they should not be driven to the lunch room or telephone. A man-up order selector has no reason to be driving in a dock area, and a sit down forklift used to load trucks likely has no reason to be driving through your narrow aisle racking areas. Allowing lift trucks to be driven where they are not used adds nothing to the productivity of your operation and creates potential for accidents.
Make sure operators use all safety equipment provided with the vehicle including seat belts for sit down vehicles and safety belts and tethers for man-up vehicles. It has been shown that many fatalities resulting from tipovers or forklifts falling from docks are the result of the operator falling from or trying to jump from the vehicle only to be crushed by the operator cage. A seat belt and other operator restraining devices will keep the operator within the cage. I'll again emphasize supervision in that it is unlikely that your operators will regularly use their seat belt unless they are forced to (although having them read OSHA's report on selected forklift fatalities may convert them).
There are also physical issues which will affect safety within your facility. Having frequent preventative maintenance to lift trucks, dock levelers, and other equipment as well as making sure aisles and traffic lanes remain uncluttered and well marked will increase your level of safety. Install physical barriers near edges of docks or other hazardous areas to protect operators and pedestrians.

I hope this articles helps you to initiate or enhance your lift truck safety initiative. I am a little surprised as to how many times I've made reference to OSHA requirements within this article as my intention was not to write an article on OSHA compliance, but rather an article on lift truck safety with some reference to the new ruling. The fact is that OSHA did such a fantastic job in the new ruling and the information and training materials they are providing that I will once again encourage anyone involved in the operation of lift trucks to read these materials. If you haven't already been to the OSHA site GO THERE NOW!

A Note on Impact Alarms.

Impact alarms are devices that can be attached to lift trucks that sense impacts; they have been around for years and are available from several manufacturers. Companies often purchase impact alarms after they have achieved a certain level of aggravation brought on by unreported lift truck damage to racks, inventory, or other equipment. The concept being that when a lift truck driver hits a rack, an alarm will sound thus notifying his supervisor (and everyone else) of the incident (and guilty party). The reality is that these devices are frequently purchased, installed, then promptly turned off. The problem is that lift trucks take a lot of jolts that are not collisions. Driving over dock levelers, cracks in floors, or debris on floors constantly set off these alarms (requiring the supervisor to then come running to turn it off). While you can adjust the sensitivity of these devices, by the time you have tuned the sensitivity to a point where it is not going off when you don't want it to, it probably is not going to go off when you do want it to (it does not take much of an impact to bend pallet racking).

For years I've advised against installing these devices in most facilities because of these problems. However, there have been some technological advances in recent years that are starting to show some promise in solving these issues. In one case, a company integrated location tracking through a Wi-Fi network that then logged the time and location of the impacts into a computer (no alarm). Then, if you find damage in the warehouse, you can review the logs to see if an impact was logged in that physical location. While this doesn't really solve the problem of false positives, it does provide a workable compromise. Obviously this is going to be more costly than the simple standalone impact device mounted to the truck.

Update: Seatbelt Use

I recall reading about a debate within OSHA related to enforcement of seatbelt use. This is probably due to complaints by operators and businesses. It seems as though OSHA is trying to relax the policy and only require seat belts under certain operating conditions (such as only with specific tasks in specific areas of the plant). The problem with this logic is, that if workers are not required to wear the safety belts all the time, they will very likely not wear them when they are needed ( either intentionally or because they "forgot"). I'll admit that I didn't think much of safety belt use until I read the specifics of lift truck fatalities. After reading these, I was convinced that seatbelts should be required.