Editor’s Note: This is the first of three parts.
Our industry tends to focus on the core product issues: concrete finishing challenges, new forming methods, and decorative techniques, to name a few. However, secondary daily operations also deserve our attention. Using forklifts falls into this category. Whether it’s moving forms or loading trucks, we use forklifts every day to handle heavy loads. This three-part series will discuss the safe and productive use of forklifts in our industry.
Forklift operation requires the operator to be trained and certified, which is often an overlooked requirement of the OSHA Regulations. In a warehouse, it is common for the forklift operator’s job to be a full- time position, making it a little easier to manage that individual’s training and credentials. On a jobsite, it’s common to see the closest available worker jump on the forklift to unload an arriving truck, making it imperative that a company ensures that everyone understands what the requirements are for a forklift operator.
The OSHA Construction Industry Regulations (29 CFR 1926.602) state that the General Industry regulations regarding forklift operations apply equally to work on construction sites. These regulations (29 CFR 1910.178) clearly list the requirements for training and certifying a forklift operator. It is important that a contractor understand the meaning of the term “certified” as it applies to this section because the term takes on different meanings throughout the Regulations.
This subpart clearly states that the employer must do the certifying. This means that there is no validity to a third party-issued “forklift operator certification” credential without some further specific action on the part of the employer. The regulations state that an employer may rely on such credentials as evidence of prior training. However, the employer must still conduct its own assessment of the individual’s skills and abilities, and must ensure the employee is trained and proficient on the specific equipment. The employer must also ensure and certify that the operator has been trained in the hazards that he may encounter.
29 CFR 1910.178 and its appendix contains a very specific list of training items and topics for forklift operators. It is also very specific about the certification process. It states that an operator must undergo training and a series of evaluations before he is considered certified. An employer must conduct these evaluations and maintain proper documentation. An employer that does not have the personnel qualified to conduct these evaluations may hire a third party to perform the training and the assessments. Although an employer can use a third party, the employer still must certify each operator.
Everyone must understand who is authorized to operate a forklift under the given circumstances. In one of my previous operations, we attempted to run everyone through the training and certification process, hoping this would mean we could stick with our then-current procedures where the closest available person jumped on the forklift. In the process we identified several people who had no business operating a forklift from safety and productivity standpoints. We learned this valuable lesson during controlled training where there was no risk of injury. Going forward, we used hard hat stickers to identify people who were certified and authorized to operate the forklift, making it easy for anyone to recognize who should and shouldn’t be on a forklift.
There are many variables on a construction site. Using a forklift under these conditions necessitates a site-specific hazard assessment to choose the right piece of equipment and train the operator to recognize and avoid hazards. In my next column, I will discuss hazard assessments, site conditions, and daily inspection requirements.
Jim Rogers is director of the Western OSHA Education Center at the Del E. Webb School of Construction, Arizona State University. E-mail firstname.lastname@example.org.