OSHA and Yard Tractor Operators

It’s a little-known fact OSHA considers yard tractors (also called mules, or hostlers, among other names) to be “powered industrial trucks” covered under 1910.178.  These are the tractors used for moving and spotting trailers around loading docks.

In a June 27, 2011 letter to safety trainer Bob Pfister, OSHA stated “Yard tractors that are not designed to U.S. Department of Transportation (DOT) specifications for over-the-road use would be considered a powered industrial truck per 29 CFR 1910.178(a)(1), and the definition of a powered industrial truck outlined in American National Standards Institute (ANSI) B56.1 – 1969. ANSI B56.1-1969 was one of the source national consensus standards for OSHA’s Powered Industrial Trucks standard. Vehicles that are approved for over-the-road use by the DOT would not be considered powered industrial vehicles and would be exempt from 29 CFR 1910.178.”

Yard tractor drivers are required to be provided training that meets the 1910.178 requirements.  The only exception is for trucks that are primarily intended to be used on the public roads.  However, almost every truck yard has a mule or two that are designed and intended for use only in truck yards, and are covered by these rules.  If your yard tractor has no license plates, there’s a clue for you right there.

Under OSHA’s Powered Industrial Truck training rules, the following is required:

  • Training must consist of a combination of formal instruction and practical training, which includes training on features and operation of the truck as well as conditions in the areas in which it will be used,
  • plus a record of the training, and
  • an initial evaluation to be repeated every three years.

If an operator has previously received training in a topic specified in the rule, appropriate to the truck and working conditions, additional training in that topic is not required if the operator has been evaluated and found competent to operate the truck safely.  Don’t assume that a driver who has a valid CDL won’t need to have the OSHA training.  Having a CDL isn’t necessarily enough.  Did the CDL training include a review of the particular hazards of operating a truck in your lot?  Was there a hands-on portion to cover the specific controls and features of the yard truck?

Although certainly not high on the OSHA radar, it is a rule that can come into question if there is an accident or complaint concerning these trucks.  There has been at least one OSHA Review Commission decision in which the defendant was required to prove that they had adequately trained their yard tractor drivers.  If you have yard trucks that stay in the yard, the training the drivers get merits checking into.


  1. If a yard truck has license plates and can be used on the road then the driver must have a CDL correct? My question is this – if said yard truck is plated and the driver is operating it and the driver has a CDL does the driver have to follow all the rules and regulations that over the road drivers have to adhere to? Mainly the HOS rules.

    Comment by Jeff — December 9, 2013 @ 5:07 am

  2. William H. Kincaid

    Good question – according to DOT “CMVs used wholly on private property not open to public travel (such as yard hostlers and yard tractors in a motor carrier’s terminal) are
    exempt from all the FMCSRs.” OSHA exempts yard tractors with license plates for road use, so we have an interesting situation where very little regulation applies. It would be up to the employer to determine safe hours of service.

    Comment by William H. Kincaid — July 24, 2014 @ 5:31 am

  3. needing some guidance on yard tractor training

    Comment by Judy Chapman — January 5, 2015 @ 3:30 pm

  4. William H. Kincaid

    You can use the OSHA rule as a guideline, but the content will have to be different. Some truck manufacturers offer their own yard truck safety videos and training – such as Kalmar’s: https://www.youtube.com/watch?v=1Pm15lL91DY. Capacity also has their full training video posted on youtube.

    Comment by William H. Kincaid — January 5, 2015 @ 4:33 pm

  5. Me podrían decir si aquí cerca de los Ángeles californiana hay una escuela de aprendizaje para las yard goat ( mulas por favor.

    Comment by Javier Rodríguez — January 6, 2015 @ 8:44 pm

  6. William H. Kincaid

    Mi consejo sería que pedir al distribuidor local de camiones si ofrecen entrenamiento. Gracias.

    Comment by William H. Kincaid — January 8, 2015 @ 5:47 pm

  7. If an employee is going to drive this yard dog, do they need to do a pre-use inspection with documentation? Our drivers already have a PIT license but just learning about needing something for the yard dogs.

    Comment by Cathy Michelbrink — May 14, 2015 @ 6:46 am

  8. Good afternoon,

    Can anyone tell me who is responsible for securing the trailer’s nose jack stand of a uncoupled tractor before and after loading the trailer? The lift truck operator and/or the yard tractor operator.


    Comment by William Taylor — June 11, 2015 @ 12:02 pm

  9. were in Chicago I can get a spotter certification I couldn’t find a place?

    Comment by gary chapple — June 26, 2015 @ 10:30 am

  10. William H. Kincaid

    Gary, I would start with the company that provides your yard trucks. These distributors are generally well-versed in where to find training, or have their own trainers on staff.

    Comment by William H. Kincaid — June 26, 2015 @ 10:33 am

  11. William H. Kincaid

    The responsibility to set the jack stand can be assigned to either per the company’s dock rules, but the ultimate responsibility for making sure it’s done belongs to the forklift operator who loads and unloads the truck, per OSHA. NOte OSHA doesn’t say who does it, just who makes sure it gets done.

    Comment by William H. Kincaid — June 26, 2015 @ 10:36 am

  12. William H. Kincaid

    The way I understand it the pre-shift inspection applies to any type of industrial truck, so yard dogs would be included. Obviously the inspection would be different from the one you might give a forklift, but the essential safety ares would need to be addressed at the start of the shift.

    Comment by William H. Kincaid — June 26, 2015 @ 10:37 am

  13. Is a golf cart used in an industrial setup such as maintenance and construction considered a powered Industrial truck?

    Comment by Elio Romero — July 8, 2015 @ 6:14 am

  14. William H. Kincaid

    One might think golf carts are included in the standard because they are designed to carry people and light loads, are not licensable for over-the-road, are not construction vehicles and are not used in agriculture. However, in a letter of interpretation to Mr. Bob Pfister, OSHA said “ANSI/National Golf Car Manufacturers Association (NGCMA) Z130.1-2004 defines a golf car as, “a vehicle used to convey a person or persons and equipment to play the game of golf in an area designated as a golf course.” Golf cars are considered by design to be recreational vehicles and are exempt from 29 CFR 1910.178. Again, it is the design of the vehicle that is the determining factor of whether or not it is considered a powered industrial truck, rather than the manner in which it is utilized.” Not completely trusting that 100% of all OSHA inspectors would be aware of this interpretation, I did a search of OSHA citations for any involving golf carts and found a couple. A good interpretation to keep handy in the event your company gets cited under 1910.178 for no golf cart training!

    Comment by William H. Kincaid — July 8, 2015 @ 11:03 am

  15. i work for the usps as a yard spotter am i required to wear a seatbelt in the yard for every move i do not go out on the road thanks gregg

    Comment by gregg johnson — July 31, 2015 @ 5:35 pm

  16. William H. Kincaid

    Greg, I know this is not necessarily good news, but yes, you should be wearing your seatbelt, as required by OSHA policy. It may seem like more trouble than it’s worth when driving at low speed in a lot but if you don’t have your seatbelt on you basically don’t have the protection of the vehicle. The injuries you would be exposed to if your truck was hit by one of the rigs in the lot would be worse than what they would be if you were wearing your seatbelt. I know 10 or 15 miles an hour doesn’t seem fast enough to require a seatbelt. Imagine running as fast as you can and heading straight into an oak tree. That’s a 15 mile an hour collision into a fixed object without a seatbelt. If you want to consider colliding with another vehicle traveling that same speed, just double it. I’m sure this sounds preachy, so I should add I was in a low speed head-on collision back in my younger days before I started wearing a seatbelt all the time like I do now. The feeling of regaining consciousness after knocking out my car’s windshield with my face is still pretty easy to remember – a Mike Tyson TKO punch on steroids.

    Comment by William H. Kincaid — August 1, 2015 @ 8:59 am

  17. Do I need a CDL for a day cab with single axle? Its main purpose is a yard shifter but once a week it has to be taken for fuel the round trip is less than ten miles on road ?

    Comment by Jeffrey Shay — August 7, 2015 @ 12:46 pm

  18. William H. Kincaid

    The Federal Motor Carrier Safety Administration defines a Commercial Motor Vehicle (CMV) this way: A motor vehicle or combination of motor vehicles used in commerce to transport passengers or property if the motor vehicle: 1) Has a gross combination weight rating of 26,001 or more pounds inclusive of a towed unit with a gross vehicle weight rating of more than 10,000 pounds; or 2) Has a gross vehicle weight rating of 26,001 or more pounds, or 3) Is designed to transport 16 or more passengers, including the driver; or 4) Is of any size and is used in the transportation of materials found to be hazardous for the purposes of the Hazardous Materials Transportation Act and which require the motor vehicle to be placarded under the Hazardous Materials Regulations.

    I can’t guess what the GVWR might be, so we can’t conclude anything from that here, but it sounds like the tractor will not be towing a load and will not crossing state lines. It is used in a lot, and only leaves the yard to refuel, unloaded. That makes me think it’s not a CMV. If it’s technically not a “commercial vehicle”, then a CDL would not be required to take it out on the road. It would be worth a call to the state DOT office to verify because – vexingly – each state has its own spin on what’s a CMV and what’s not.

    Comment by William H. Kincaid — August 7, 2015 @ 2:04 pm

  19. If a spotter truck is licensed, road-worthy and used on public roads even sparingly, it would not be subject to OSHA seat belt regulations as a powered industrial truck.
    However, if it is not licensed and never used on public roads then it is subject to OSHA regulations under 1910.178.
    Is this a correct understanding?

    Comment by michael metzger — August 20, 2015 @ 10:12 am

  20. William H. Kincaid

    To my understanding, OSHA does not consider licensed, roadworthy the vehicles to be “powered industrial trucks”. Therefore your conclusion seems to be correct. Also, OSHA has stated in one of the interpretations quoted elsewhere in the comment section the following:

    “…it is the design of the vehicle that is the determining factor of whether or not it is considered a powered industrial truck, rather than the manner in which it is utilized.”

    Following that logic, a vehicle designed for use on public roads would not be designed to be an industrial truck. I’m a little unsure as to that applying to yard tractors without license plates, however. The only reason most yard tractors ever enter a public roadway is to be taken for fueling or to the repair shop. They are designed to be used shuttling trailers for short distances in yards, and that’s about it. I think having the vehicle registered and putting a license plate on it even if it is designed for occasional road use is important in excepting it from the powered industrial truck rule.

    Comment by William H. Kincaid — August 20, 2015 @ 10:31 am

  21. If a business has warehouses on both sides of the street and a dead end street or circle do I need a CDL to drive across and between warehouses

    Comment by Denny Luna — November 10, 2015 @ 9:51 pm

  22. William H. Kincaid

    Since 1992, anyone who drives a commercial vehicle on public streets is required to have a CDL. I think that applies in the situation you described as well. Look at it this way – what if a passenger car was on the street and you backed into it with the truck? You and the driver of the car would have to exchange drivers license information, right? And if the police were there, the first thing they would ask you for would be your drivers license. And your drivers license would have to be the right kind of license for the vehicle you’re driving. An ordinary passenger car drivers license wouldn’t seem to be the right thing for a tractor pulling a 52 foot long trailer. One might make the argument that it is not used in interstate commerce, but that is a tricky one as the Federal and state DOT’s have a way to stretch that definition to fit almost any situation where cargo may be involved such as in moving a loaded trailer. Their argument is if it is being moved as part of a process of it going from one state to another, even if it is being picked up and dropped in the same state, that is still interstate commerce. I’ve given up on trying to find situations that are clearly not interstate commerce when there is an interstate load involved. So, yes, I think the CDL is required.

    Comment by William H. Kincaid — November 11, 2015 @ 3:27 am

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