TWI BULLETIN NO. 7

Temporary Worker Initiative

Powered Industrial Truck Training 

This is part of a series of guidance documents developed under the 

Occupational Safety and Health Administration’s (OSHA’s) Temporary Worker 

Initiative (TWI). This Initiative focuses on compliance with safety and health 

requirements when temporary workers are employed under the joint 

employment of a staffing agency and a host employer.

Temporary workers are entitled to the same 

protections under the Occupational Safety and 

Health Act of 1970 (the OSH Act) as all other 

covered workers. When a staffing agency supplies 

temporary workers to a business, typically, the 

staffing agency and the staffing agency’s client 

commonly referred to as the host employer are 

considered joint employers of those workers. Both 

employers are responsible for determining the 

conditions of employment and complying with the 

law. In these joint employment situations, questions 

regarding how each employer can fulfill their duty 

to comply with the standard are common. This 

bulletin addresses what both the staffing agency 

and the host employer can do to provide powered 

industrial truck training to temporary workers under 

OSHA general industry standard 29 CFR 1910.178(l), 

Powered Industrial Trucks or 29 CFR 1926.602(d) in 

construction (the standard). 

Powered industrial trucks, commonly called 

forklifts, fork trucks, lift trucks, pallet jacks, 

and order pickers are used in many industries, 

primarily to move materials. They can be driven 

by an operator or controlled remotely by a walking 

operator. There are many types of powered 

industrial trucks and each has its own unique 

characteristics and some inherent hazards. 

Training

The standard requires employers to develop and 

implement a training program based on the general 

principles of safe-truck operation, the types of 

vehicle being used in the workplace, the hazards 

of the workplace created by the use of the vehicle, 

and general safety requirements. To be effective, 

training must address the unique characteristics of 

the type of vehicle the temporary worker is being 

trained to operate.1 Prior to operating a powered 

industrial truck, employers must ensure that each 

operator has successfully completed the training. 

Trained operators must show that they can perform 

the job safely and proficiently by demonstrating 

these skills in a workplace evaluation. 

Training must consist of a combination of the 

following:

• Formal instruction (e.g., lecture, discussion,

interactive computer learning, video training,

documents);

• Practical training (demonstrations and exercises

performed by the trainee);

• Refresher training;

• Evaluation of the operator’s performance in the

workplace; and

• Certification of training and evaluation.

1. Whether a temporary or permanent worker, it is a violation of

Federal law for anyone under 18 years of age to operate a forklift.

See 29 CFR part 570, www.osha.gov/dts/shib/shib093003.html.
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Host Employer and Staffing 

Agency Responsibilities

The host employer and staffing agency share 

responsibility for training temporary workers in 

operating powered industrial trucks. The training 

requirements for a powered industrial truck 

operator are performance-oriented. This permits 

employers to tailor a training program to the 

characteristics of the workplace and the specific 

types of powered industrial trucks operated.2

Determining the best way to protect workers 

from injury largely depends on the type of truck 

operated and the hazards of the worksite. While 

both the host employer and the staffing agency 

are responsible for ensuring that the employee 

is properly trained in powered industrial truck 

operations, the employers may decide that a 

division of the responsibility may be appropriate.

As a recommended practice, the staffing agency 

and host employer should jointly review the task 

assignments and job hazards that would include 

the type(s) of powered industrial trucks workers will 

operate to identify and eliminate potential safety 

and health hazards. The details of the training and 

protections each employer will provide can be 

clearly established in the language of the contract 

between the host employer and the staffing 

agency. However, neither employer may avoid 

its ultimate responsibilities under the OSH Act by 

requiring another party to perform them.

Generally, the staffing agency is responsible for 

generic powered industrial truck training and the 

host employer is in the best position to provide 

the necessary site-specific powered industrial 

truck training and evaluation, as the host employer 

is most familiar with the equipment being used 

and controls the conditions of the worksite. Such 

training and evaluation should be the same as that 

provided to the host employer’s own employees 

in the same jobs. Both staffing agencies and 

host employers must ensure that temporary 

workers receive proper generic and site-specific 

2. Use of seatbelts: Employers are required to train employees

in all operating instructions, warnings, and precautions listed in

the operator’s manual for the type of vehicle which the employee

is being trained to operate. Therefore, operators must be trained

in the use of operator restraint systems (seatbelts) when it is

addressed in the operating instructions. See: CPL-02-01-028,

Compliance Assistance for the Powered Industrial Truck Operator

Training Standards.

training and evaluation. It is the staffing agencies’ 

obligation to take reasonable steps to inquire 

about the host employer’s training program and 

have a reasonable basis for believing that the 

host employer’s powered industrial truck training 

adequately addresses the potential hazards of 

operating powered industrial trucks to which 

its employees might be exposed at the host 

employer’s worksite.

Refresher training is required whenever an 

operator demonstrates a deficiency in the ability 

to safely operate the powered industrial truck or 

an incident involving a powered industrial truck 

has occurred. The need for refresher training 

may be recommended by the staffing agency if 

the temporary worker is involved in an incident, 

but the need for refresher training is usually best 

determined and provided by the host employer. 

If the staffing agency supplies trained powered 

industrial truck operators, the host employer must 

still verify that training and provide site-specific 

information and training on the particular types of 

powered industrial trucks and working conditions 

present at the worksite. The host employer must 

also conduct a workplace evaluation of each 

operator supplied by the staffing agency. The 

extent of the training and evaluation provided 

by the host is based upon the operators’ past 

experience and may not need to be duplicated or as 

extensive as the initial training and evaluation.3

Employers must certify that each operator receives 

the training and evaluation, and also re-evaluate 

each operator at least once every three years. If 

the staffing agency is providing trained powered 

industrial truck operators, it may be in the best 

position to keep training and evaluation records. In 

such cases, the host employer may choose, but is 

not required, to maintain or store additional copies 

of the powered industrial truck training records of 

temporary workers. However, the host employer 

must know where the training and evaluation 

records are located and they must be accessible to 

an OSHA compliance officer during an inspection. 

As a recommended practice, the host employer and 

3. See 1910.178(l)(5); CPL 2-1.28A Training, Evaluation, and

Certification by a Third Party; and Frequently Asked Questions

About Powered Industrial Truck Operator Training at www.osha.

gov/dte/library/pit/pit_q-a.html.
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staffing agency may agree to share training records 

to ensure both parties are able to verify that the 

training is completed. 

Communication between the staffing agency 

and host employer is essential to ensure that 

the worker is competent in the operation of the 

powered industrial trucks being used. In addition, 

communication between the staffing agency and 

the temporary worker is crucial to ensure that 

the worker is not being assigned to work with 

powered industrial trucks that he or she may not 

be competent to operate. If the staffing agency 

determines that their workers are operating 

powered industrial trucks and are not trained or 

are inadequately trained, then the staffing agency 

should inform the host employer so that the host 

employer provides adequate site-specific powered 

industrial truck operator training, provide the 

training itself, or remove its workers from the host 

employer’s worksite. 

Example Scenario*

A warehousing and distribution company, MWC Distributors (MWC), needs workers to fill 

orders for an upcoming surge in production. The company contracts with Temp Staffing to 

provide warehouse workers to pick up orders and load trucks. Temp Staffing supplies five 

temporary workers previously trained in the general operation of powered industrial trucks, 

including sit-down order picker trucks, and sends them to work on site at MWC. Prior to the 

work commencing, Temp Staffing meets with MWC to review the tasks and type of equipment 

the workers will operate. At the meeting, MWC learns from Temp Staffing that the workers were 

previously trained and operated the same type of picker trucks as the ones they would operate 

at MWC. However, the parties agree that the temporary workers would still need site-specific 

training at MWC’s worksite. 

At the worksite, a supervisor from MWC assigns the temporary workers to the warehouse area 

to move pallets of metal parts to the loading dock area. The supervisor reviews the site-specific 

aspects of the warehouse including equipment, traffic flow, and loading operations with the 

temporary workers. He also provides the workers with an overview of the picker truck and 

emphasizes the mandatory use of seat belts while operating the trucks. 

After a few days, one of the temporary workers operating the picker truck hits a stack of 

pallets on the warehouse floor when turning too sharply around a corner. The worker’s 

vision is obscured by the height of the load being carried. There are no injuries, but the pallet 

being transported overturns. After the incident, MWC determines that refresher training 

and evaluation is in order for that temporary worker operating the truck to ensure that he is 

competent in its operation. 

Analysis

MWC and Temp Staffing have a joint responsibility to ensure that temporary workers are 

protected from hazards of operating powered industrial trucks. In this scenario, the two 

companies communicated prior to sending workers to the site and reviewed the scope of 

work, equipment, and the necessary training. While MWC provided the required site-specific 

instruction, it should have also determined whether the workers were competent to operate 

the picker trucks. MWC may be subject to OSHA citation(s) under the powered industrial 

truck standard’s training requirements for failing to evaluate the worker’s competency before 

operating the equipment. 
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Temp Staffing provided training to workers in the general use of powered industrial trucks and 

also verified the type of equipment to be used at MWC. However, because Temp Staffing may 

not have provided adequate training or evaluated the workers’ competency, Temp Staffing 

may also be subject to an OSHA citation under the powered industrial truck standard’s training 

requirements for failing to provide adequate generic training and failing to ensure the worker’s 

competency was evaluated before beginning work. 

Although the two companies did not discuss evaluation of the workers, they did communicate 

prior to the work commencing, and they discussed training and the tasks to be performed. 

Following the incident, MWC did appropriately conduct the required refresher training and 

evaluation of the temporary worker operating the equipment.

*The company names used in this scenario are fictitious. Any resemblance to real companies is entirely coincidental.

State Plans

Twenty-eight states and U.S. territories have 

their own OSHA-approved occupational safety 

and health programs called State Plans. State 

Plans have and enforce their own occupational 

safety and health standards that are required to 

be at least as effective as OSHA’s, but may have 

different or additional requirements. A list of the 

State Plans and more information are available at: 

www.osha.gov/dcsp/osp. 

How Can OSHA Help?

Workers have a right to a safe workplace. If you 

think your job is unsafe or you have questions, 

contact OSHA at 1-800-321-OSHA (6742) or visit 

OSHA’s main web page at www.osha.gov.

It’s confidential. We can help. 

For other valuable worker protection information, 

such as Workers’ Rights, Employer Responsibilities 

and other services OSHA offers, visit OSHA’s 

Workers’ page www.osha.gov/workers. 

For information on Temporary Workers visit 

OSHA’s Temporary Workers’ page www.osha.gov/

temp_workers. 

For information on powered industrial truck 

training visit:

• Safety and Health Topics, Powered Industrial 

Trucks-Forklifts — www.osha.gov/SLTC/

poweredindustrialtrucks

• E-Tools Powered Industrial Trucks (Forklifts), 

Training Assistance — www.osha.gov/SLTC/

etools/pit/assistance

• Powered Industrial Trucks-Operator Training (MS 

PowerPoint Presentation) — www.osha.gov/dte/

library/pit/ppt/pit-pp97.ppt

• Sample Daily Checklists for Powered Industrial 

Trucks — www.osha.gov/dte/library/pit/daily_pit_

checklist.html

The OSH Act prohibits employers from retaliating 

against their employees for exercising their rights 

under the OSH Act. These rights include raising a 

workplace health and safety concern with either 

employer, reporting an injury or illness, filing an 

OSHA complaint, and participating in an inspection 

or talking to an inspector. If workers have been 

retaliated or discriminated against for exercising 

their rights, they must file a complaint with OSHA 

within 30 days of the alleged adverse action to 

preserve their rights under section 11(c). For more 

information, please visit www.whistleblowers.gov.
OSHA also provides help to employers. OSHA’s 

On-site Consultation Program offers free and 

confidential advice to small and medium-sized 

businesses in all states and several territories, 

with priority given to high-hazard worksites. 

On-site consultation services are separate from 

enforcement and do not result in penalties or 

citations. Consultants from state agencies or 

universities work with employers to identify 

workplace hazards, provide advice on compliance 

with OSHA standards, and assist in establishing 

and improving safety and health management 

systems. To locate the OSHA On-site Consultation 

Program nearest you, call 1-800-321-6742 (OSHA) 

or visit www.osha.gov/consultation.

Disclaimer: This bulletin is not a standard or regulation, and it creates no new legal obligations. It contains 

recommendations as well as descriptions of mandatory safety and health standards. The recommendations are 

advisory in nature, informational in content, and are intended to assist employers in providing a safe and healthful 

workplace. The Occupational Safety and Health Act requires employers to comply with safety and health standards 

and regulations promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, the OSH Act’s 

General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free from 

recognized hazards likely to cause death or serious physical harm.

For more information

Occupational

Safety and Health

Administration

www.osha.gov (800) 321-OSHA (6742) U.S. Department of Labor

OSHA 3889-09 2016