Finally, many small businesses choose to conduct their own training, and requiring them to become accredited to do so would be unnecessarily burdensome. Since the proposal, OSHA has changed the language of the final rule to clarify that the employer does not need to administer the training but may have it provided by an outside training provider. OSHA proposed that operators must successfully complete their training and be evaluated. OSHA believes that evaluation is an essential element of any training program. Evaluation provides a measure not only of the effectiveness of the training but also the trainees' ability to understand the need for and the important elements of the training.
Evaluation also allows the trainer to reemphasize the most important points of the training.
Most of the 32 participants who commented on this issue agreed that some evaluation is necessary when training is conducted. There was general agreement on the need to conduct written as well as practical testing during the training. Specific requirements for how to test operators would take away the flexibility allowed by the currently proposed language, convert the rule to a specification standard, and greatly increase the information collection burden without necessarily improving the safety performance of operators. On the other hand, six commenters generally supported the need for the trainee to perform all the necessary procedures correctly during practical tests. Their concerns were that if the trainee cannot operate the vehicle safely when that trainee knows that an evaluation is being conducted, there is no guarantee that the trainee will perform the operation correctly under less controlled circumstances.