When designing your forklift training program, you must include three mandatory components: formal instruction, practical (hands-on) training, and a performance evaluation of each operator in the actual workplace. This isn’t optional or flexible. OSHA standard 1910.178 spells out exactly what a compliant program looks like, and skipping any of the three components can result in citations and fines, even if your operators have years of experience.
The Three Required Components
Every forklift training program must combine all three of these elements. You can’t substitute one for another, and completing an online course alone doesn’t satisfy the requirement.
- Formal instruction: This can take many forms, including classroom lectures, written materials, videos, interactive computer-based learning, or group discussion. The goal is to cover the knowledge an operator needs before they ever touch the equipment.
- Practical training: The trainer demonstrates how to operate the forklift, and the trainee then performs hands-on exercises under supervision. This must happen on the type of truck the operator will actually use.
- Performance evaluation: A qualified evaluator watches the operator handle the forklift in the real workplace environment and confirms they can do so safely. This is not a written test. It’s a live assessment.
Truck-Related Topics You Must Cover
Your formal instruction needs to address a specific list of vehicle-related topics. These aren’t suggestions. OSHA expects your program to walk operators through each one for the type of truck they’ll be authorized to drive:
- Operating instructions, warnings, and precautions specific to that truck
- How the forklift differs from a car (rear-wheel steering, elevated center of gravity, different braking behavior)
- Location and function of all controls and instruments
- Engine or motor operation
- Steering and maneuvering
- Visibility limitations, especially those caused by loads
- Fork and attachment use, including limitations
- Vehicle capacity and load limits
- Vehicle stability (how loads, speed, and turning affect tip-over risk)
- Pre-shift inspection and maintenance the operator will perform
- Refueling or battery charging procedures
- Any additional warnings or precautions from the manufacturer’s operator manual
That last point matters more than people realize. If the truck’s manual includes specific precautions, your training program needs to incorporate them. A generic, one-size-fits-all course won’t cover manufacturer-specific details for every model in your fleet.
Workplace-Specific Topics You Must Cover
Beyond the truck itself, your program must address the conditions operators will actually face in your facility. This is where many programs fall short, because it requires tailoring the content to your specific site rather than relying on off-the-shelf training.
OSHA requires coverage of:
- Floor and surface conditions (wet concrete, uneven outdoor yards, dock plates)
- Types of loads being carried and how stable they are
- Load stacking and unstacking procedures
- Pedestrian traffic patterns in operating areas
- Narrow aisles and tight spaces
- Hazardous locations (areas with flammable materials or classified atmospheres)
- Ramps, inclines, and sloped surfaces
- Enclosed or poorly ventilated areas where exhaust fumes could accumulate
- Any other unique hazards at your worksite
If your warehouse has a freezer section with slippery floors, that needs to be in the training. If operators cross a loading dock with a grade change, that needs to be addressed. The standard is designed so that operators are prepared for the real hazards they’ll encounter, not a theoretical version of a warehouse.
What the Performance Evaluation Looks Like
The hands-on evaluation should test operators on every phase of forklift use they’ll perform on the job. A thorough evaluation covers five core areas.
Pre-use inspection. The operator should walk around the truck and check for visible damage, fluid leaks, tire condition, and proper function of controls before starting.
Picking up a load. Evaluators watch whether the operator squares up to the load’s center, stops about a foot away before inserting the forks, levels the forks before driving forward, lifts smoothly, tilts the mast back to stabilize the load, checks over both shoulders before moving, and lowers the load to travel height before driving.
Traveling. The operator should maintain a safe speed, keep the load low, observe all traffic signs and floor load limits, slow down at corners, sound the horn at intersections, follow other vehicles at a safe distance, and keep arms and legs inside the cab. On ramps, the load should face uphill.
Setting down a load. This mirrors the pickup sequence in reverse: confirming clearance, squaring up, raising to placement level, moving forward slowly, lowering the load into position, checking both shoulders, and backing straight out before lowering forks to travel height.
Parking. Forks must be fully lowered, controls neutralized, brakes set, and power turned off. On an incline, wheels should be blocked. Operators should only park in designated areas.
If your operators handle refueling or battery charging, the evaluation should also confirm they shut the engine off first, have a fire extinguisher nearby, wear proper protective equipment, and clean up any spills immediately.
Who Can Conduct the Training
Your trainer must have the knowledge, training, and experience to both operate the specific equipment and teach others to use it safely. OSHA interprets this practically: if your facility uses specialized attachments and the trainer has never operated a truck with those attachments, that trainer isn’t qualified to teach or evaluate others on that equipment.
The trainer doesn’t need to operate a forklift as part of their regular job duties. But they do need the practical skills and judgment to safely operate the equipment under the conditions present in your workplace. There’s no formal certification OSHA requires for trainers, but the standard places the burden on the employer to verify that whoever leads the training actually has the relevant competence.
Refresher Training and the Three-Year Rule
Initial training isn’t the end of your obligation. OSHA requires refresher training or retraining whenever an operator is involved in an accident or near-miss, observed operating unsafely, assigned to a different type of truck, or working in a facility where conditions have changed significantly (new racking layouts, different floor surfaces, or different types of loads).
Even if none of those triggers occur, every operator must be re-evaluated at least once every three years. This evaluation confirms they’re still operating safely and haven’t developed bad habits. It doesn’t need to be a full retraining, but the evaluation itself is mandatory on that three-year cycle.
Certification Records You Must Keep
After each operator completes training and passes evaluation, you need to certify them in writing. The certification must include the operator’s name, the date of training, the date of evaluation, and the identity of the person who performed the training and evaluation. Keep these records accessible. They’re the first thing an OSHA inspector will ask for after a workplace incident involving a forklift.
There’s no required format for the certificate, but it needs to contain all four elements. Many employers use a simple form or card, while others maintain a digital database. What matters is that you can produce the documentation on request and that it reflects the actual training delivered, not a generic template with names filled in.