OSHA 1910.38 and 1910.39: What Your Drill Records Need to Show
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Learn what OSHA requires for forklift safety training: who needs it, what it must cover, three-year evaluations, certification records and penalties.
Forklifts move the materials that keep warehouses, manufacturing plants, distribution centers and construction sites running. They also cause serious injuries and deaths every year. Powered industrial trucks were linked to 67 worker fatalities in 2023, and they remain one of the standards OSHA cites most often.In OSHA's preliminary fiscal year 2026 data, Powered Industrial Trucks (29 CFR 1910.178) ranked seventh among all standards, with 1,379 citations. Most of those citations trace back to the same gap: operators who were never properly trained, evaluated or certified.
The good news is that OSHA's rules are clear. This guide covers what forklift safety training must include, how evaluation and certification work, what non-compliance costs, and how to build a program that holds up in an inspection.
OSHA's forklift training rules live in 29 CFR 1910.178(l), the operator training section of the Powered Industrial Trucks standard. It applies to general industry, and OSHA applies the same training requirements to construction. The standard covers more than sit-down forklifts: reach trucks, order pickers, pallet jacks with riders, motorized hand trucks and tow tractors all count as powered industrial trucks.
The core requirements are:
One point trips up many employers: OSHA puts the responsibility on the employer, not the employee. A worker who arrives with a card from a previous job or an outside course still needs site-specific training and an evaluation by your company before driving your trucks.
OSHA lists the topics a training program must address, split into truck-related and workplace-related subjects. You can skip a topic only if it truly doesn't apply to the trucks or conditions at your site.
Truck-related topics:
Workplace-related topics:
Because training has to match your trucks and your facility, generic online courses only satisfy the formal instruction portion. The hands-on practice and the evaluation must happen on the equipment and in the conditions your operators actually face.
Operators should also learn the daily pre-use inspection. OSHA requires trucks to be examined before being placed in service, at least daily, or after each shift when trucks run around the clock. Defective trucks must be taken out of service until repaired.
There is no such thing as a forklift license issued by OSHA. OSHA forklift certification is a written record created by the employer confirming that an operator has been trained and evaluated under the standard. That certification must include:
Every operator must have their performance evaluated at least once every three years. The evaluator watches the operator perform real tasks in the workplace and confirms they still operate safely. If the evaluation shows gaps, the operator needs refresher training before continuing.
Three years is the maximum, not the schedule. Refresher training, with an evaluation of its effectiveness, is required whenever:
This is why incident and near-miss reporting matters for forklift compliance. If a near miss goes unreported, the refresher training it should have triggered never happens.
If an operator already received training on a topic and was evaluated as competent, you don't need to repeat that topic. You still need to evaluate them yourself and cover anything specific to your trucks and site before they operate.
The competency training requirement, 1910.178(l)(1)(i), is one of the most frequently cited serious violations in general industry. Inspectors typically find the same handful of problems:
OSHA did not adjust its penalties for inflation in 2026, so the 2025 maximums remain in effect:
|
Violation type |
Maximum penalty (2026) |
|
Serious |
$16,550 per violation |
|
Other-than-serious |
$16,550 per violation |
|
Failure to abate |
$16,550 per day past the abatement date |
|
Willful or repeated |
$165,514 per violation |
Each untrained operator can be a separate citation, so costs climb quickly at sites with large fleets. Direct penalties are also only part of the bill. Workers' compensation claims, damaged product and racking, downtime and legal costs from a single forklift incident can far exceed the fine.
Source: OSHA 2026 civil penalties memo
A strong program does more than check the OSHA box. It gives you a repeatable process and records you can produce in minutes when an inspector asks.
Spreadsheets and paper binders make steps 5 and 6 hard to sustain as operators come and go. A centralized training management system can store certifications, flag evaluations before they lapse and assign refresher training automatically when an incident is logged.
Forklift safety training isn't a one-time event. OSHA expects a cycle: train, evaluate, certify, watch for triggers, retrain and re-evaluate at least every three years. Employers who treat it as an ongoing program, tied to incident reporting and inspections, prevent injuries and stay off OSHA's most-cited list.
EHS Insight helps safety teams manage that cycle in one place. Track operator certifications and evaluation dates, get alerts before they expire, link incidents and near misses to refresher training, and pull audit-ready records whenever you need them. Request a demo to see how it works.
How often is forklift safety training required?
OSHA requires an evaluation of each operator's performance at least once every three years. Refresher training is required sooner if an operator drives unsafely, has an accident or near miss, fails an evaluation, moves to a different type of truck, or faces workplace changes that affect safe operation.
Does OSHA issue forklift licenses or certifications?
No. OSHA doesn't license operators or approve training providers. The employer trains, evaluates and certifies each operator, and keeps that record on file.
Is online forklift training OSHA compliant?
Only in part. Online courses can cover formal instruction, but OSHA also requires hands-on practical training and an evaluation in the workplace. An online certificate alone doesn't meet the standard.
Is forklift certification transferable between employers?
Not entirely. A new employer can avoid repeating topics an operator has already mastered, but must still evaluate the operator and cover any truck types and site conditions specific to the new workplace.
Who can conduct forklift training?
Anyone with the knowledge, training and experience to train operators and evaluate their competence. That can be an in-house supervisor, a safety professional or an outside trainer.
Do pallet jacks require forklift training?
Motorized pallet jacks are powered industrial trucks, so operators need training and evaluation under 1910.178(l). Manual, non-powered pallet jacks are not covered by the standard.
How old must a forklift operator be?
Under federal child labor rules, workers must be at least 18 to operate a forklift in non-agricultural jobs.
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