Skid Steer Safety Training
Skid Steer Safety Training Frequently Asked Questions:
What are the OHS skid steer loader standards?
Contrary to popular belief, neither OHS nor ANSI have issued standards specific to skid steer loader operation. This is, we assume, in part to the versatility of this type of construction equipment in that on any given day they can be used as loaders, backhoes, forklifts, mowers, and the like. Currently, SAE J1388-2013 is the only standard that applied to skid steers and personnel protection.
If I’m operating the skid steer as a backhoe or a forklift, does the machine and operations fall under OHS earth moving and forklift standard?
No. This, too, is a common misunderstanding. According to OHS March 7th, 2000 Letter of Interpretation, if the “equipment was designed to move earth buy has been modified to accept forks,” then “it would not be considered a powered industrial truck within the scope of 1910.178,” the standard for low and high lift trucks. Some might argue that they did not “modify” the equipment to use forks and that it was created for this purpose in addition to using it as a loader. True, but the keyword here is “in addition.” It was originally intended to be an earth mover, so no matter how often you use the forks, it will not fall under the forklift standard.
Then why not the earth moving standard? Good question. One of these days soon it may, or it may have its own standard. But just know that right now, because of the big differences in size and operation when compared to 360 excavators and loader backhoes, it does not fall under their OHS standard either.
Does OHS require skid steer safety training?
Yes, absolutely. OHS has a few key standards that are a “catch-all” of sorts. 29 CFR 1926.20 and 21 lay the general ground work for safety training requirements—no matter the equipment or situation. Simply put, these two standards state very clearly that it is the employer’s responsibility to train operators. More specifically, 1926.21(b)(2) states that “the employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.”
Bottom line, if you don’t train and there is an accident, and OHS comes in to investigate (and they will), you better believe they will ask for proof that workers have been trained (when and on what subjects). And if you can’t prove it, they will most likely refer to these standards and the OSH Act of 1970 as the basis for their citations.
Do I need additional skid steer safety training if I am using different attachments?
Yes. In line with the standards mentioned above, operators need to be trained on the safe operation of the machine, as well as any attachments. Why? Because they are all different in terms of safe operation and handling. So, if you will be using a backhoe attachment, you should first receive additional training regarding its use. The same goes for buckets, pallet forks, hoppers, sweepers, and the like. Also, it cannot be overstated: operators must read and understand the operator’s manual for both the skid steer and the attachment before use.
How often do I need skid steer safety training?
OHS requires skid steer safety training for operators–on that there is no question. Where confusion exists is how often operators need refresher training or re-certification. Outside of the initial safety class, OHS requires operators be re-evaluated every three years to determine if they are still competent enough to operate.
However, this every-three-year evaluation is the maximum time that is allowed by OHS to pass before an operator receives recertification. According to OHS, there are several instances that will require additional training and observation before the three year period is up:
- The operator is observed in an accident or a near miss
- The operator received a poor evaluation or is observed driving in a dangerous manner
- The operator is assigned to drive a different type of skid steer or the workplace has changed significantly enough to require additional training (such as being transferred from a warehouse to a dock or a construction site)
I’ve received skid steer training. Can I operate a track loader or multi-terrain loader?
Not necessarily. OHS requires operators to receive training for each type of skid steer. On this term, “type,” there is much confusion. Generally speaking, by “type” OHS means skid steer vs. compact track loader or multi-terrain loader. But, perhaps more than any other piece of equipment, skid steer operations can vary widely by machine size and capacity. So different sized skid steers—even within the same brand–could also qualify as different types.
If you have received skid steer safety training and have always operated a rubber-tired CAT skid steer, but then are asked to operate a rubber-tired John Deere skid steer, you should be just fine to operate under the same training certification received previously. Keep in mind though, controls can differ greatly from brand to brand, especially among skid steers (Dual-Lever Foot Controls vs H-pattern Controls vs. ISO Joystick Controls vs ACS), so in these cases you may need additional instruction or a quick refresher training to make sure you are clear on what each control does.
At the end of the day, if you were operating a backhoe loader and there was a backhoe loader accident and OHS came to investigate only to discover that you had received training specific to 360 skid steers but not backhoe loaders, then you’d be liable. You can’t really train too much.
I’ve operated skid steers for 20 years. Do I need to take a class, a written exam, and a practical exam still? Or can I just take a written test?
No matter how long you’ve been on the job, OHS requires skid steer safety training, a skid steer written exam, and a practical skid steer evaluation. There is no way around it. This goes for other types of skid steer loaders too. The extent of the classroom skid steer safety training can be adapted by the instructor according to student needs. The written exam proves mental competency and understanding of the safety principles taught. And the practical evaluation proves the skid steer operator not only understands but is capable of operating the machine safely.
I received skid steer safety training at a different job. Do I need to be trained again by my new employer?
This is a common question, especially among laborers-for-hire who may sub out from job to job. Technically, it is your current employer who is responsible for saying whether or not you have been trained. If you bring a training certificate or wallet card to your new employer, they do not have to accept it. It is their right to require you to take their own training class. This is because if there is an accident, they will likely be responsible and need to prove to OHS that they trained you on safe skid steer operations.
What is skid steer certification? Who can train, evaluate, and certify operators?
This, above all, causes a lot of confusion. Bottom line, OHS states that employers are responsible to train their employees. Generally speaking, there are three ways they can do this:
- Train employees in-house with their own program
- Hire a 3rd party to train the employees (on-site or off-site)
- Use another company’s materials or online classes to train employees
In terms of using a 3rd part of a safety training companies materials (like our skid steer training kits on CD or Digital Download or our online skid steer safety training) OHS does not recognize one company over another. They simply state that ‘training needs to occur’ and ‘here are the things a skid steer operator should be trained on.’
When we do live or online skid steer safety training, people often assume we are the ones certifying the trainees. This is not true for any training company. We are simply assisting the employer by providing live training or the training materials needed to help them certify their employees for safe skid steer operation.
Do I have to wear a seat belt when operating a skid steer loader?
First, most construction equipment today are designed with interlock control systems that prevent them from working or the lift arms from rising without the seat belt and restraint bars being engaged. On a side note, you should never disable the interlock control device. But if your skid steer does not have a seatbelt, then the choice is yours. Technically, OHS does not have a specific standard that requires the use or installation of seat belts.
BUT, the OSH Act of 1970, specifically 5(a)(1), which is still in effect today, states that “each employer shall furnish to each of his employees…a place of employment which is free from hazards that are causing or are likely to cause death or serious physical harm to his employees.” That means the employer needs to take measures to prevent injuries in the case of a common accident—like tip over. In this case, wearing a seatbelt is one of the primary ways to protect an operator so you should always wear it. If you don’t and you get injured, OHS will most likely fine you for not wearing it.
Do I have to wear a hard hat in a skid steer?
Like seat belts, there are some grey areas regarding when an operator needs to wear a hard hat. Much of the responsibility falls on the employer to create rules, and the employees to follow them. What we do know is that OHS 29 CFR 1910.135(a)(1) states, “each affected employee shall wear protective helmets when working in areas where there is a potential for injury to the head from falling objects.” “Affected employees” is defined any “employees who are exposed to the hazards.”
Add to that the OSH Act of 1970 we’ve already discussed, and you have enough information to make the decision on your own.
How does this relate to skid steers? If you are in a cab that is enclosed, and if you are wearing your seatbelt and the lap bar has been secured, then you might be okay. The cab is small, though, so in a roll over you still might injure your head.
If, however, the cab is not enclosed, the likelihood of being hit by an object or debris falling from the bucket increases. In these cases, it is still up to the employer to set forth any PPE requirements, but it would be wise to wear your hard hat no matter what.
How do I take the skid steer practical evaluation if I take the training online?
The online skid steer training class covers OHS requirements for the classroom portion. Many employers prefer online training because they know exactly what training the operator will receive. In live classes, the training sometimes varies. A written exam is included at the end of our online training courses. After the class and exam are finished, you and your safety managers will have immediate access to a practical evaluation checklist. This can be printed off and used by your supervisor to help him or her evaluate you on the skid steer. When done, they can sign it and file it with your exam. This will satisfy OHS requirements for skid steer certification.
My trainee scored 80% on the exam. Did he pass or fail?
Contrary to popular belief, OHS does not dictate what a passing score entails. That is ultimately up to the employer whose responsibility it is to certify, or authorize, their employee to operate a skid steer. If you want to pass him at 80%, fine. But what if a question or two among the 20% missed could lead to an accident or death? Is it worth it? Our recommendation is that you always go over any missed questions with your trainees—even if they just missed one. Once they understand the principle missed, have them write their initials by the correct answer. That way, you are protecting them and those around them from potential accidents in the future.