By Brian Colburn, Contributor
OSHA came into existence in 1970 with very basic rules on Powered Industrial Trucks (PIT). The PIT standards went unchanged until 1999, when updates on training went into effect. OSHA is again considering changing the PIT standard, but there is no set timeline for the revision at the moment, and it could take years.
We thought it might be helpful for employers to know where OSHA puts much of its focus with regard to the PIT standards. During one three-year period, the top six PIT-related citations accounted for over 11,000 total citations—nearly 72% of all PIT citations. Of these particular six top areas, they fall into two distinct categories: training and maintenance. Training accounted for 39.5%, and maintenance for 32.1% of overall PIT citations.
Training is Serious Business
The training part is divided into a few key portions. First, OSHA expects employers to ensure operators are competent and go through the required training per the standard. Just to clarify: Employers need to take the word “competent” very seriously. Taking a person off the street who has never before driven a PIT and expecting them to be competent after a two-hour class and 10 minutes of driving time is akin to putting a person in an aircraft alone after one take-off and landing and expecting them to function as a commercial pilot. Moral of the story is to take the time and effort to ensure operators understand safe operation and also are fully comfortable using each type of PIT at your site, and are able to do the tasks you will ask them to perform.
Secondly, the employer must “certify” every PIT operator has been trained and evaluated. Just training them, without documenting it was completed, is not sufficient. It can’t be stressed enough: document, document, document. From the classroom score, to how many hours of practice time, to the final hands on evaluation—put it all in writing.
The last training pitfall is failing to provide refresher training and re-evaluations. These may sound like the same thing, but they are not. To paraphrase, refresher training in relevant topics must be conducted when you observe the operator operating unsafely; if they have a near miss/accident; or if you evaluate them and find they are not operating safely.
Refresher training must also be conducted if the truck type changes or if a condition in the workplace changes. Keep an eye on your operators; constantly evaluate if they are operating safely, as well as following the rules, if not provide refresher training. Learn from your near misses/accidents and use that information to ensure the same things don’t happen again at your site or any other company locations.
Maintenance is Key
The next part of the puzzle is maintenance-related. First, OSHA expects you to inspect every PIT, for every shift it is used. If you operate only one shift, it will be daily; if you run around the clock, it will be two or three times, depending on the length of the shift. There is not an hour limit on the shift, so if you run two, 12-hour shifts you will inspect it twice daily. If you run three, eight-hour shifts, you will inspect it three times daily.
We would suggest referring to the PIT’s operator’s manual to decide what items need to be checked and on what timeframe. Contrary to popular belief, OSHA does not require these inspections to be in writing, and OSHA has a letter of interpretation about this on their website. That being said, it may be impossible for you to prove to OSHA you are doing them, if you don’t have it documented—so document it 100%.
Most companies are doing one of two things for inspections. The old-school method is a paper checklist. However, the problem with paper lists is that when audited, most sites can’t produce a consistent record for every PIT and every shift over time. The other problem is with the system for removing unsafe PIT’s from service. It’s very bad if the operator finds a brake problem and documents it, but the PIT still remains in service for days. The other method is a forklift monitoring system, which will be discussed below in greater detail.
Secondly, OSHA expects companies to remove unsafe PITs from service until properly repaired. If I had a dollar for every defective or unsafe PIT I saw in use out in the field, I would be a rich man. Any company that feels they have no unsafe or defective PITs in operation should take a closer look at every PIT in their fleet or have a professional do so.
It’s uncommon for me to find a site where there are no safety issues of any type on any PIT. If you subscribe to OSHA’s newsletter update called OSHA QuickTakes, you will find citations for this on a regular basis. If you are not yet subscribing to QuickTakes, you should be; it’s a wealth of safety information, and it’s free of charge. It’s important to put a system in place to document inspections; audit it to be sure it’s working 100% of the time; and remove unsafe forklifts from service immediately—no matter how important they are to your operation.
It’s worth mentioning that more and more companies are using forklift monitoring systems to ensure the first operator on each shift completes the checklist. If the operator doesn’t complete the checklist, the system will not let the PIT operate that shift. These also allow the company to create critical and non-critical designations for each checklist item. Non-critical items can be reported to management electronically, but the PIT can continue working. When critical items fail, the PIT is removed from service, and management is alerted.
If you train operators and maintain your PITs properly, you will have eliminated 71.6% of your potential OSHA PIT citations. That’s great for safety and good money math too!
About the author: Brian Colburn of Forklift Training Systems, a leader in forklift safety training and products. www.forklifttrainingsystems.com