Forklift Safety Program: OSHA Requirements and What to Document

Forklifts kill about 85 workers per year and seriously injure around 34,900 more, according to OSHA. The leading causes are tip-overs, pedestrians struck by the truck, and workers falling from forks used as a makeshift work platform. All three are preventable with a program that actually gets followed.

OSHA 29 CFR 1910.178 has been a top-10 most cited standard for years. The violations aren’t technical. They’re documentation failures: operators who were never formally evaluated, inspection records that don’t exist, and pedestrian controls that look good on paper but aren’t enforced on the floor.

What OSHA 1910.178 Actually Requires

The standard covers powered industrial trucks, which includes sit-down counterbalanced forklifts, reach trucks, order pickers, pallet jacks, and other variations. Requirements apply to all of them.

The core obligations are a formal operator training and evaluation program, pre-shift inspections with documented results, a speed and traffic control program appropriate to your facility, and procedures for maintaining equipment in safe condition. The standard also requires safe operating rules that reflect your actual workplace, not just OSHA’s generic list.

OSHA does not issue forklift “certifications.” The standard requires training and evaluation by a qualified person. What comes out of that process is an operator who has been evaluated as competent on a specific truck type in your specific workplace. Any certification card from a third-party training provider covers only classroom content. It does not satisfy OSHA’s requirement for site-specific, hands-on evaluation.

See forklift certification requirements for more detail on what third-party training covers and where it falls short of the OSHA requirement.

What Operator Training Must Cover

Training has two components: truck-specific content and workplace-specific content. Both are required.

Truck-specific content covers how the truck operates. That means load capacity and the load plate, stability characteristics and the stability triangle, controls and instrumentation, engine or motor operation, steering and maneuvering, visibility limitations, refueling or recharging procedures, and vehicle inspection. An operator trained only on a sit-down counterbalanced truck is not trained on a reach truck. Each truck type requires separate training.

Workplace-specific content covers where the truck will be used. Surface conditions, ramps, grades, and floor load ratings. Pedestrian traffic patterns and high-risk zones like dock areas and aisle intersections. Hazardous locations including areas where flammable vapors or dust might be present. Recharging or refueling station locations. Closed environments where carbon monoxide from propane trucks can build up.

OSHA lets you reduce training content for operators who have previous experience on the same truck type in a similar environment, but you can’t skip the evaluation. Even experienced operators must be evaluated in your facility before operating alone.

The Practical Evaluation Requirement

Classroom training and a written test don’t satisfy OSHA. The standard requires a practical evaluation by a qualified person who can observe the operator actually driving the truck in the work environment.

The evaluation covers the operator’s ability to perform pre-shift inspections, start and shut down the truck safely, operate controls, travel with a load and without one, position and stack loads, operate on ramps or in areas with grade changes, and manage pedestrian interactions at key choke points in your facility.

Document the evaluation separately from the training. The record needs to show the operator’s name, the truck type, what was evaluated, who did the evaluation, and when it happened. A single sheet per operator per truck type is sufficient. But you have to have it.

The evaluator must be qualified to operate the truck type being evaluated. A safety manager who has never operated a reach truck cannot conduct a valid reach truck evaluation.

The 3-Year Rule and When You Must Retrain Sooner

OSHA requires refresher training and a new evaluation at least every 3 years. Four events also require refresher training before that interval.

If an operator is observed operating a truck unsafely, you must retrain before they continue. An observed safety violation triggers the requirement, whether or not an incident occurred. The same applies to a near-miss or accident involving the operator. An evaluation that shows deficiencies also requires retraining, not just a counseling conversation.

Assigning an operator to a different truck type is the fourth trigger. An operator certified on a sit-down counterbalanced forklift cannot legally operate a reach truck without training and evaluation on that specific type.

Keep a matrix of each operator, each truck type they’re authorized on, and their evaluation date. That matrix is what an OSHA compliance officer will ask to see if there’s a forklift-related incident on your site.

Pre-Shift Inspections: What to Check and How to Document It

OSHA requires a pre-shift inspection before each use. For trucks used on multiple shifts, the inspection happens at the start of each shift. The inspection must check for any defects that could make the truck unsafe.

Items to check include tires for wear, cuts, or damage. Forks for cracks, bends, or wear at the heel. Mast for proper function and damage. Hydraulic system for leaks, damaged hoses, and proper fluid level. Overhead guard and load backrest for integrity. Lights and horn. Seat belt or operator restraint. Fire extinguisher if required by your program. Battery, fuel, or LP gas level.

The inspection must be documented. OSHA doesn’t specify a form, but a dated checklist with the operator’s signature and the truck’s ID is the industry standard. Keep completed checklists. Inspections without records may as well not have happened from a compliance standpoint.

When a deficiency is found that affects safe operation, remove the truck from service immediately. Tag it out. Don’t let the operator continue the shift on a truck with a hydraulic leak or cracked fork because it “seems fine for now.” That’s a citation waiting to happen, and it’s how equipment failures turn into incidents.

Only a qualified mechanic should clear a tagged truck for return to service. The return-to-service sign-off should also be documented.

Pedestrian Traffic Controls

Struck-by incidents involving pedestrians are a consistent source of forklift fatalities. Most facilities have mixed pedestrian and forklift traffic, and the controls for separating them determine who gets hurt.

Physical separation is the most reliable control. Where budget and layout allow, dedicated forklift aisles with barriers or raised curbing work better than painted lines. Lines fade, get ignored, and don’t stop a forklift traveling at 7 mph.

Where physical separation isn’t practical, use floor markings with enforced right-of-way rules. Forklift aisles should be a different color than pedestrian walkways, with sufficient width for the truck plus load plus 3 feet of clearance on each side. Mark intersections clearly and post yield signs for forklift operators at blind corners.

Speed limits must be posted and enforced. A sit-down counterbalanced forklift traveling at 9 mph has roughly the stopping distance of a car at 35 mph at that scale. Post limits appropriate to your surface conditions and aisle layout. Enforce them the same way you’d enforce any other safety rule.

Dock areas and staging areas are high-risk zones. Dock doors where trucks back in and turn present pedestrian hazards that are harder to control with floor markings alone. Consider physical controls: chains across dock openings, pedestrian entry restrictions during active loading, and spotter requirements when visibility is limited.

Stability Triangle and Load Capacity

Tip-overs are the leading cause of operator fatalities. They happen when the load’s center of gravity moves outside the stability triangle, the three-point contact area formed by the two front wheels and the rear axle pivot point.

Every forklift has a data plate showing rated capacity at a specific load center, typically 24 inches from the face of the forks for standard counterbalanced trucks. Load something heavier or with a center of gravity further from the forks and the effective capacity drops. An operator carrying a 4,000 lb load with a 36-inch load center on a truck rated for 4,000 lbs at 24 inches is already overloaded.

Train operators to read the data plate on every truck they’re assigned. Include capacity calculations in your site-specific training for operators who handle non-standard loads. Overloading is not just an OSHA violation. It’s the mechanism behind tip-overs that kill operators.

Never remove or alter a data plate. Never modify a truck without manufacturer approval and a revised data plate.

Common OSHA Forklift Citations

OSHA’s most common 1910.178 citations, based on inspection data, are operators who have no documentation of being evaluated, pre-shift inspection records that are missing or incomplete, modified or damaged equipment still in service, and operating rules that exist in the written program but aren’t enforced on the floor.

The no-evaluation citation hits hard because employers often have training records from third-party courses but no in-house evaluation records. OSHA distinguishes between the two. Training from a vendor covers truck-specific knowledge. Workplace evaluation is your responsibility.

For broader context on how OSHA cites employers and what the penalty ranges look like, see the OSHA fines and penalties guide. If you’re building out a full safety program, a job hazard analysis for forklift operations in your specific facility will identify pedestrian exposure points and loading area hazards that generic training won’t cover.

The employer safety training requirements guide covers how OSHA’s training documentation standards apply across programs beyond just forklifts.

FAQ

The Bottom Line

When OSHA shows up after a forklift incident, the first thing they ask for is your operator evaluation records. Not your training sign-in sheets. Not your certificates from a vendor course. The evaluation records that show an authorized person observed your operator on your truck in your facility.

If those records don’t exist, you don’t have a compliant program. Start there.