Richard E. Fairfax, director of OSHA’s Directorate of Enforcement programs, has backed off his ill-conceived proposal: “At this time, OSHA has decided not to make any changes to its Compliance Directive CPL2-128A Powered Industrial Truck Operator Training (PITOT) regarding the use of operator restraints.” That’s old news (MHM, July 2003).
What’s new is that this was a proposal that should never have been made because:
• Many companies — usually small users of lift trucks — were just starting to get familiar with the PITOT standard and how they would have to comply. Fairfax’s proposal would have weakened enforcement of the new regulation.
• Lift truck operators who didn’t like seat belts were encouraged to ignore them by Fairfax’s proposal. After he backed off, the trainers had to start over.
• Enforcement of the seat belt part of the PITOT regulation was on hold for nine months while Fairfax was trying to make up his mind.
Let’s go back to the beginning with the seat belt regulation.
First, the PITOT standard indirectly refers to seat belts when it says: “Any other operating instructions, warnings, or precautions listed in the operator’s manual for the types of vehicle that the employee is being trained to operate.” In other words, if your lift truck comes equipped with seat belts, its operator has to be trained in their use. That’s the basic seat belt regulation.
Remember that PITOT is a training standard and cannot mandate the use of seat belts. (I make this point to keep you from losing money to somebody who wants to bet you on this point.) However, if one of your operators has an accident while not wearing a seat belt, it would be hard to prove that he wasn’t obliged to wear the belt.
Unfortunately, the emphasis Fairfax put on seat belts overshadowed the need for total enforcement of the PITOT standard. PITOT has three basic mandates. First, the operator must be trained on the type of truck he uses on the job. Second, he must be trained in the environment he experiences on the job. Third, he must be evaluated by a qualified person (or persons) and a record kept of the training and evaluation.
(The training and evaluating may be done by an independent trainer, but don’t forget that your company can’t pass off responsibility for compliance.)
The training must be formal — classes, videos, lectures, written materials, whatever works best for your company — and practical, which means demonstrations by the trainer and driving exercises by the operator.
Don’t forget that refresher training must be provided to an employee when he has been involved in a near-miss (or other condition spelled out in the standard). Likewise, every operator’s performance must be evaluated at least once every three years.
Finally, as the standard says, “The employer shall certify that each operator has been trained and evaluated ...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.”
Those are the basics of complying with the PITOT standard. There’s more to the lift truck than just the seat belt.
Bernie Knill, contributing editor