As you already know OSHA routinely visits work premises and conducts an inspection to assure regulations and laws are strictly followed and businesses are compliant.
During the course of the inspection and assessment, the employer must show some kind of documentary evidence to prove their conformity with the current forklift training standards.
According to OSHA’s Powered Industrial Trucks, 29 CFR 1910.178(l)(6), “the employer shall certify that each forklift operator has been trained and evaluated as required by this paragraph (l). The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation."
To sum up what requirements to produce, you must retain on file the attendance training sheets with the name and signatures of the trainees, date of the training conducted, type/subject of forklift training course, name of the trainer with his signature affirming the training he performed, test papers answered during the classroom training, performance evaluation sheet rated by trainer during the practical demonstration and proofs of skill competency attained by the trainees (you can keep photocopies of the operator cards and training certificates issued to successful trainees).
For How Long Must I keep Forklift Operator Records?
For you to have evidence to show to OSHA, you must maintain a file of the operator training records. It doesn’t matter if you use computer-based recording or just a typical paper-based filing, what’s important is you have to be able to show confirmation of your training record when asked by OSHA inspector. The inspector wants to see if the training is up-to-date and refresher courses are given regularly.
Training record should be maintained every three years which is the recommended duration for you to supply refresher course to the workers. The record should also be retained whenever a new training or performance assessment is carried out.
It would be much more ideal if you must keep a file of each of your forklift operator as long as he is still employed with the company. It would also be helpful for you to maintain a record even if the worker is no longer connected just in case the worker is rehired by the company (in cases such as retrenchment and layoff, or if the person is temporary and seasonal, or re-supplied by job agency). Retain the documentation during the workers’ employment or at least a minimum of five (5) years.
This clears the fact that OSHA doesn’t have specific requirements for how long and for how many years should you retain forklift training records. It is just a good practice to maintain the file in case of an internal company audit as well.
Keeping a record can also help the training personnel to assess the issues that could be lacking. This can also assist him to evaluate the progression of the trainees and monitor the things that need to be supplied.
Training must be kept tracked so that operators can be given forklift refresher course which is at least once every three years.
What Would Be the Consequence If You Failed to Maintain Records?
It will sting you if you failed to maintain training records simply because you have no evidence to show to OSHA that could lead to penalty and fines. OSHA can impose tens to hundreds of thousands of dollars in fines, depending on the gravity of the situation.
If a serious accident happened in the workplace, the most common assessment to be done by OSHA is to dig through your training file and conduct an interview of the people involved. If OSHA established cause accident and concluded it was the employer’s failure to supply necessary training, then be prepared pay fines.
Imposition of penalties for not training the operators is handled by OSHA and they can enforce fines as much as $200,000 depending on the seriousness and weightiness of the violation.
It is the employer’s liability to provide the forklift operator the required training prior to commencing work. If the operator is not trained to drive a certain type of truck, it is the employer’s duty to supply him the training needed for that kind of truck.
If the Forklift Training Is Conducted Outside the Company, Ask the Training Provider for the Copy of the Record
It is always essential to have a copy of the record whether the forklift training is performed on-site or outside the company premises. There could be an instance when you opted to hire a third party training provider/school to supply the training and you sent the operators to their facility to receive the training. In such case, you can ask the training provider to furnish you a copy of the attendance sheet, operator card and certificate given to your forklift operators.
OSHA needs a written record which includes the name of the operator, dates of the training and evaluation and the name of the trainer who performs the training and evaluation. When you ask the copy of the record from the training school, remember those details.
The latest OSHA Standard CFR 1910.178 requires employers that employ forklift operators to provide the necessary and adequate training to their workers in the safe use this piece of heavy equipment.
By following the OSHA regulations, you will assure conformity the law, avoiding hefty fines and penalty. You also create a safe working environment that boosts morale and confidence of the workers.
In order for you to have documentary evidence that supports your compliance to the regulations, always keep the record of the forklift training that you’ve supplied to your workers. This is mandatory!