Get Your Program in Top Shape
Direct supervision by someone with the knowledge, training, and experience to train and evaluate powered industrial truck operators is required.
THE supervisor is on his daily walkthrough inspection when he notices damaged products staged to be shipped that morning. Upon inspection, it is clear a forklift caused the damage. There is no report of damage or injury from the prior shift, and of course the operators on duty have no idea how it happened. Relieved the product was found prior to being shipped, the supervisor separates the damaged product, knowing it will mean short shipping the customer.
Product damage and injuries due to forklifts has become a reoccurring issue lately, and he is not looking forward to notifying his boss. Sure enough, his boss hits the roof when he finds out. Cost from worker's comp and property damage have been steadily increasing in the past few months, and now he needs to notify one of his most valued customers that it won't get the products it needs on time. Competition has forced thin margins and he knows this can't continue, but he just spent big bucks to have all the operators retrained and nothing has changed. Something needs to be done to get this source of rising cost under control.
Eliminating the Root Cause
It is easy and popular for management to focus solely on operator training in an attempt to improve industrial truck safety. This approach is myopic, missing the broader scope of the powered industrial truck safety issue.
The use of powered industrial trucks--which includes vehicles such as forklifts, order pickers, and motorized pallet trucks--is a common practice across industry and is the backbone of material handling. The flexibility and versatility of these vehicles has made them invaluable to the financial, retail, manufacturing, and all other sectors of our economy. As common and necessary as this equipment is, it also can be very dangerous to employees and can inflict significant damage to buildings and equipment.
OSHA reports that thousands of injuries occur each year because of powered industrial trucks. Most injuries involving industrial trucks are fairly significant in terms of cost to the employer and injuries to the employees. Implementation of a written powered industrial truck safety program is not a requirement of OSHA's standard, 29 CFR 1910.178. However, such a program could prove to be a valuable tool in the drive toward injury reduction and cost containment.
In separate studies of powered industrial truck injuries and fatalities, both NIOSH and the Ontario (Canada) Ministry of Labour found a common root cause to be the lack of an effective safety program. The studies went on to conclude that the lack of an effective program leads to poor operator training, poor operating environment, ineffective equipment maintenance, inadequate supervision, and inappropriate behaviors of the operators. A powered industrial truck program should be part of any comprehensive EHS management system.
The elements of a powered industrial truck safety program need to include the compliance requirements of the OSHA standard, additional state plan requirements, and hazards specific to the facility. A program that merely restates the requirements of the regulatory standards is of little value; the program needs to describe how these elements will be implemented and maintained. At a minimum, the following elements should be included:
- Responsibilities of the operator, supervisor, and anyone else who will be involved in the management and administration of powered industrial trucks
- Facility design
- Operating procedures
Training and Evaluation
It is unrealistic to believe that most safety professionals have the skills needed to complete all of the tasks required by the minimum elements of a powered industrial truck program. As a result, some or perhaps most of these tasks will need to be delegated to other areas of the organization.
Defining the responsibilities of everyone involved with the administration and maintenance of the program sets the standard for activities and is an important first step in developing the program. These activities need to be assigned to personnel with the appropriate skill sets. The responsibility section is also an important communication tool so everyone knows his part and how it interacts with the rest of the plan.
Defining responsibilities helps to identify training and resource needs that would not have been identified otherwise. Those listed in the responsibility section need to be included in the development of the rest of the program, along with their supervision, to ensure buy-in and commitment. One of the most important aspects of this element is determining who will have to operate a powered industrial truck, which will help to determine the scope of the program. If you have young workers, keep in mind that operating a powered industrial truck is listed as a hazardous occupation under the Fair Labor Standards Act, and as a result employees under age 18 are not permitted drive a forklift or any other industrial truck outside of the agriculture industry.
The bulk of the powered industrial truck safety program probably will be devoted to training. In 1999, OSHA revised the training requirements for powered industrial truck operators to include hands-on, practical training and evaluation, in addition to theory or formal training. The standard requires the training to include the principles of safe operation for the vehicles used in the workplace, specific and general hazards the operator may encounter while operating the vehicle, and general requirements of the standard. OSHA's 1910.178 (l)(3) lists the topics that must be included in the training content. The practical or hands-on training needs to include demonstrations by the trainer and exercises by the trainee. The trainee's performance must be evaluated to ensure he or she can safely operate the truck and perform the duties of the job.
Once training is complete, the employer is required to certify that the operator has successfully completed all of the training requirements. The certification includes the employee's name, date of training, date of evaluation, and name of the person who conducted the evaluation. Most organizations provide a license that meets the certification requirements, but licensing is not an OSHA requirement.
Retraining and evaluation are required in the following circumstances:
- The operator has been observed operating the vehicle in an unsafe manner.
- The operator has been involved in an accident or near-miss incident.
- The operator is assigned to drive a different type of truck.
- The workplace conditions change in a manner that could affect the safe operation of the truck.
It is an understandable expectation of operations management that the training be conducted by the safety professional. A problem some organizations run into is that the safety professional has little experience driving a truck. The standard requires training and evaluation be conducted by and under the direct supervision of those with the knowledge, training, and experience to train and evaluate powered industrial truck operators. Most safety professionals have the knowledge and ability to conduct the formal instruction but don't have experience at driving a truck that would enable them to demonstrate tasks or provide direct supervision during training. An experienced industrial truck operator or a supervisor with operating experience probably will have to take a part in the hands-on training and evaluation.
The proficiency of each operator needs to be evaluated once every three years.
The powered industrial truck program should specify how the training process will be completed, including how formal training, practical training, and retraining will take place. Training can be very time consuming, depending on how many types of trucks are present and the amount of retraining required.
Truck Inspections and Maintenance
Industrial trucks should be inspected at least daily prior to use. Trucks used around the clock must be inspected before each shift. Organizations that require the operator to conduct inspections should include this as part of the training.
The inspections are to be documented, which is normally done on a check sheet. The industrial truck program must outline who will conduct the inspections, how they will be documented, and what is to happen to the check sheet after they are completed. This is an item that is easily forgotten: There is little value in documenting repairs that are needed on a check sheet that is not looked at by someone who has the ability to make the needed repairs.
The powered industrial truck safety program should include how the vehicles will be maintained. Only employees who have been trained and authorized should be conducting maintenance on powered industrial trucks. It almost goes without saying that any truck that is inspected and found to be unsafe to drive must be taken out of service. There can be a strong temptation for shop floor personnel to drive a truck without a horn, with poor tires, or with soft brakes if it means keeping production going. The program must anticipate what steps will be taken to ensure the vehicles are maintained properly and to provide direction for supervision and operators in the event a truck is found to be unsafe to drive.
Facility Design and Operational Factors
Address issues of facility or workplace design in the program, including items such as:
- Selecting trucks that are appropriate for the hazards of the environment and rated load capacities
- Maintaining aisle width to allow safe passage of the vehicle and the load it is carrying.
This is also where issues of fuel type, fuel storage, and safe handling should be addressed. This section of the program could be quite different for each organization because specific organizational characteristics are addressed.
Operating procedures should outline minimum expectations for the operators. The items covered need to include all areas of operation, including inspection, traveling, loading, unloading, and parking. The OSHA standard has a long list of items that should be included as part of this section. Each facility should also conduct a hazard analysis to uncover all items specific to the operation of powered industrial trucks. The results of the hazard analysis are included in this section. Typical issues that may be identified during a hazard analysis would be blind corners, cracks or holes in the floor, narrow aisles, and forklifts that come too close to pedestrians or workstations. Include each of the issues identified in the hazard analysis in operators' training.
This is also where program enforcement is included. A program that is not enforced is a program with a quasi existence or perhaps no existence at all, except on paper. Not only is the value of the program not realized through injury and cost reductions; it can exacerbate problems by encouraging unsafe behavior. The NIOSH and Ontario Ministry studies mentioned earlier cited the lack of an effective program as a root cause of injuries; lack of enforcement will result in an ineffective program.
Pedestrian safety is not necessarily part of a powered industrial truck safety program, but it would be remiss not to touch on the subject because those of us on foot have a far greater opportunity for injury, in the event of an accident between the two.
Most injuries and accidents result from multiple causes, and injuries involving powered industrial trucks are not immune to this. Pedestrians are at times a stronger contributing factor to injuries involving powered industrial trucks than training or actions of the truck operator. It is normal to sympathize with the injured employee and focus corrective action on the driver, but the pedestrian may share a role in the incident.
The actions of the pedestrian are often neglected during investigations and are not addressed. Most safety professionals would agree that pedestrians have the right of way; however, the right of way should not give them the opportunity to put themselves in the path of a moving vehicle. The idea is similar to how most people behave as a pedestrian outside the workplace: As pedestrians we have the right of way on the public road, yet we move for oncoming traffic out of self-preservation. Pedestrians and industrial truck traffic should be separated when at all possible. When they must share or cross paths safely, expectations need to be made of the pedestrian as well as the industrial truck operator.
Ultimate Value of the Program
The powered industrial truck safety program contains many elements that are common in organizations across the country. It gains value by taking these activities and combining them into one system that can be managed, evaluated, and manipulated to provide safety improvements and cost efficiencies. Perhaps the manager in the scenario at the beginning of this article could have avoided the troubles he faces if he implemented a comprehensive powered industrial truck safety program, rather than just focusing on training.
- NIOSH Publication # 2001-109, Preventing Injuries and Deaths of Workers Who Operate or Work Near Forklifts.
- Ontario Ministry of Labour, Guideline for Safe Operation and Maintenance of Powered Industrial Trucks.
- U.S. Department of Labor Office of Training and Education training materials.
- U.S. Department of Labor Fair Labor Standards Act.
This article appeared in the July 2006 issue of Occupational Health & Safety.
This article originally appeared in the July 2006 issue of Occupational Health & Safety.