OSHA recently announced guidelines to assist inspectors in enforcing powered industrial truck operator training requirements. You can expect compliance officers to:

• Inquire about your method training and evaluating operator performance.

• Ensure that all training is conducted by a person who has the knowledge, training and experience to train operators and evaluate their competence.

• Determine if you’ve trained employees in the applicable topics listed in 1910.178(l)(3).

• Determine if your operators have received training in the operating instructions, warnings, or precautions listed in the operator's manual for the types of vehicle that they use.

• Enforce the use of seat belts where applicable under the general duty clause of the Occupational Safety and Health Act in accordance with the October 9, 1996 Seat Belt Enforcement Memorandum. (OSHA's enforcement policy on the use of seat belts on powered industrial trucks states that employers are obligated to require operators of powered industrial trucks that are equipped with operator restraint devices, including seat belts, to use the devices.)

• When possible, observe powered industrial truck operations to determine if trucks are being operated safely, and conduct employer/employee interviews to verify training program implementation.

• Determine whether the employer has certified that all required training and evaluations have been conducted. The requirement for certification and the reasons for the requirement will be explained to the employer and the action noted in the case file. The employer will also be informed of possible penalties for subsequent violations.