ISO 9001 Competency - Forklift License and Internal Auditors

[jacoblh]

Hello all,

After a fairly successful pre-audit, I feel more and more confident in the work I am doing!

That being said, I have two questions:

Is a forklift license necessary? We have a driver who has been doing this part of the job for years, I have never seen anyone more fluid with a forklift. He is not licensed. If it makes a difference, he never leaves the premises with the forklift.

I also now understand that we have to do some Internal Audit training through a 3rd party - can I do this online? Has anyone had any success or defeat with online Internal Auditing training?

Jacob

 

[howste]

Is a forklift license necessary? We have a driver who has been doing this part of the job for years, I have never seen anyone more fluid with a forklift. He is not licensed. If it makes a difference, he never leaves the premises with the forklift.

Unless there's an OSHA or other requirement, no you don't need a forklift license. What you do need is evidence (records) that the driver is competent. This can be in whatever form your organization determines is appropriate.

I also now understand that we have to do some Internal Audit training through a 3rd party - can I do this online? Has anyone had any success or defeat with online Internal Auditing training?

3rd party training isn't a requirement. If you don't currently have competent auditors or trainers in your company, then it's best to get some good training lined up. While you may be able to get by with an online course, again the thing you need is competent auditors. I've been a 3rd party auditor and seen a lot of records of poorly conducted audits. I've also taught a lot of audit classes. My (biased) opinion is that an onsite or public course with activities and instructor interaction is better than an online course for auditing. If you only get online training and the audits aren't effective then it's not really worth it. The proof is in the results though - you need to do something that results in effective auditors.

 

[Golfman25]

There are osha requirements for forklift training. But no license requirement.

 

[AlienraverX]

To your example, let's say there is an OSHA requirement that Forklift drivers recertify or refresh their training every 3 yrs.... Can/should an ISO 9001 auditor write up a finding to the standard? I say no because the standard doesn't specify that requirement and if your internal procedures don't either, well there are no grounds for an ISO write up.

 

[Sidney Vianna]

OSHA, concerned with occupational health & safety, is not a source of regulatory requirements related to ISO 9001. Nevertheless, product damage due to forklift mis-operation is a very common problem. So, if evidence shows product damage due to poor forklift operations, any risk-based thinking should lead the organization to make sure such damages are minimized, including the training of operators.

 

[Randy]

License? Nope! Is it required by ISO 9001? Not directly, but, if you haven't done the following and you're operating within the United States, Territories of Possessions you are wrong and in violation of Federal Law under US OSHA and it doesn't matter how long your driver has been driving or how safe he has been.

29CFR 1910.178(l)

Operator training.
1910.178(l)(1)

Safe operation.
1910.178(l)(1)(i)

The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l).
1910.178(l)(1)(ii)

Prior to permitting an employee to operate a powered industrial truck (except for training purposes), the employer shall ensure that each operator has successfully completed the training required by this paragraph (l), except as permitted by paragraph (l)(5).
1910.178(l)(2)

Training program implementation.
1910.178(l)(2)(i)

Trainees may operate a powered industrial truck only:
1910.178(l)(2)(i)(A)

Under the direct supervision of persons who have the knowledge, training, and experience to train operators and evaluate their competence; and
1910.178(l)(2)(i)(B)

Where such operation does not endanger the trainee or other employees.
1910.178(l)(2)(ii)

Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.
1910.178(l)(2)(iii)

All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.
1910.178(l)(3)

Training program content. Powered industrial truck operators shall receive initial training in the following topics, except in topics which the employer can demonstrate are not applicable to safe operation of the truck in the employer's workplace

1910.178(l)(4)

Refresher training and evaluation.
1910.178(l)(4)(i)

Refresher training, including an evaluation of the effectiveness of that training, shall be conducted as required by paragraph (l)(4)(ii) to ensure that the operator has the knowledge and skills needed to operate the powered industrial truck safely.
1910.178(l)(4)(ii)

Refresher training in relevant topics shall be provided to the operator when:
1910.178(l)(4)(ii)(A)

The operator has been observed to operate the vehicle in an unsafe manner;
1910.178(l)(4)(ii)(B)

The operator has been involved in an accident or near-miss incident;
1910.178(l)(4)(ii)(C)

The operator has received an evaluation that reveals that the operator is not operating the truck safely;
1910.178(l)(4)(ii)(D)

The operator is assigned to drive a different type of truck; or
1910.178(l)(4)(ii)(E)

A condition in the workplace changes in a manner that could affect safe operation of the truck.
1910.178(l)(4)(iii)

An evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years.
1910.178(l)(5)

Avoidance of duplicative training. If an operator has previously received training in a topic specified in paragraph (l)(3) of this section, and such training is appropriate to the truck and working conditions encountered, additional training in that topic is not required if the operator has been evaluated and found competent to operate the truck safely.
1910.178(l)(6)

Certification. The employer shall certify that each operator has been trained and evaluated as required by this paragraph (l). The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation.
1910.178(l)(7)

Dates. The employer shall ensure that operators of powered industrial trucks are trained, as appropriate, by the dates shown in the following table.
If the employee was hired: The initial training and evaluation of that employee must be completed:
Before December 1, 1999 By December 1, 1999.
After December 1, 1999 Before the employee is assigned to operate a powered industrial truck.

 

[Ron Rompen]

Unless I miss my guess, somewhere in your documentation, you will state that you will comply with all applicable laws and regulations. If you are not complying with an OSHA regulation, then the auditor is fully within his rights (and responsibilities) to document the nonconformance.

 

[Sidney Vianna]

then the auditor is fully within his rights (and responsibilities) to document the nonconformance.

An auditor performing an audit to ISO 9001 should NOT be delving into occupational health & safety, environmental, data security, etc... regulatory requirements, as clarified in this ISO paper.

 

[Golfman25]

An auditor performing an audit to ISO 9001 should NOT be delving into occupational health & safety, environmental, data security, etc... regulatory requirements, as clarified in this ISO paper.

I pretty much agee. But concerned about the last part of the paper. Auditors aren't lawyers.

 

[Randy]

I pretty much agee. But conceded about the last part of the paper. Auditors aren't lawyers.

Agreed, but the catch here is that in a case like this competence is defined by a regulatory requirement (US OSHA), that being an operator of a "forklift". The employer has no leeway in the how of competence achievement, so the process is established for the employer to follow including the recording of the achievement and so on.

The auditor is compelled to verify that the OSHA requirement for competence including the training and all that other stuff is being met, but not a "legal/regulatory" requirement but as a "procedure/process or whatever.

The caveat to all this is the relationship of the forklift/industrial truck operator to product and/or anything else that could effect product, customer property. Just because an organization has forklifts and operators doesn't mean that they are automatically "fair game" or "in scope" for the auditor to look at, relevance and relationship has to be established before we auditors can look at equipment operations like a forklift/industrial truck.

Sidney is absolutely correct in his post and I'm continuously challenged when working with a few other auditors that want to play safety or environmental guy going totally off scope when we are doing a quality only audit.

Ron is not correct in his statement primarily because as auditors we are not compliance enforcers and a good many quality people do not possess the "competence" to delve into the regulatory arena. Getting into out of scope regulations opens "Pandora's Box".