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.