April 8, 1999

Mr. Jerry M. Gillooly
Safety Director
Bohl Equipment Company
534 Laskey Road
Toledo, Ohio 43612

Dear Mr. Gillooly:

This is in response to your letter of February 17, requesting compliance assistance from the Occupational Safety and Health Administration (OSHA) regarding the revised powered industrial truck operator training standard 29 CFR 1910.178.

Your specific inquiry concerned 1910.178(l)(4)(ii)(D), which requires refresher training in relevant topics when the operator is assigned to drive a different type of truck. Refresher training compliments the initial training required by paragraph 178(l)(3) and serves to reinforce that initial training. The type and amount of training needed in refresher training when the operator is assigned to drive a different type of truck depends on factors such as the different characteristics of the different or new type of truck. For example, an operator who has been trained and evaluated in the use of a sit down counterbalanced rider truck would need refresher training if that operator is assigned to operate an operator-up counterbalanced front/side loader truck or a rough terrain forklift truck because of the different characteristics of the two trucks. Conversely, operators would not require refresher training when they are assigned to operate the same type of truck with a different manufacturer unless the truck has different characteristics.

Please be advised that 178(l) provides a performance-oriented and cost-effective approach to refresher training. When operators have been trained, evaluated, and certified by the employer as required by 178(l) in the use of different types of trucks, they would not require refresher training simply because they are assigned to operate one of those trucks.

Thank you for your interest in occupational safety and health. If you have any further questions please contact Mr. Wil Epps of my staff at (202) 963-1850.

Sincerely,

Richard Fairfax, Director
Directorate of Compliance Programs