Front End Loader Safety Training FAQs

Front End Loader Safety Training Frequently Asked Questions:
What are the OSHA front end loader standards?
Generally speaking, OSHA’s 1926 standard covers earth moving equipment and operations. As far as training goes, OSHA makes it very clear in 1926.21 and the OSH Act of 1970, which is still in effect, that operators must be trained and that training must be recorded. There is no way around it.

If I’m operating the front end loader as a forklift, does the machine and operations fall under OSHA’s forklift standard?
No. This, too, is a common misunderstanding. According to OSHA’s 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. But, in the same breath, OSHA encourages trainers to refer to the forklift standard when training as the means of understanding principles that operators may need to be trained on prior to using loader fork attachments.

Does OSHA require front end loader training?
Yes, absolutely. OSHA 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 OSHA 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 front loader 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 front loader and the attachment before use.

How often do I need front end loader training?
OSHA requires front end loader traning for front end loader operators–on that there is no question. Where confusion exists is how often operators need front end loader refresher training or recertification. Outside of the initial safety training class, it is common to see companies set recertification at every three years. We are one of them. And here’s why:

As far as this 3-year front end loader training certification goes, OSHA regulations are very specific when it comes to forklifts and a couple other pieces of equipment. However, on everything else they are not so clear. They just state the employer must regularly provide safety training for their aerial lift operators. Following industry best practices, we’ve adopted this 3-year term in order to help employers comply with the general standard of regularly providing and proving front end loader training. Ultimately, it is up to the employer to determine how frequently their front end loader operators need to be trained. Many of our customers require it more often, annually even. Others may stretch it out a bit. In working with OSHA, though, it is our experience that they like to see employers adopt the strictest standard when the regulations are not clear. For instance, we know of companies that didn’t train every three years and were reprimanded by OSHA for not offering additional training more often. It is not uncommon for OSHA to refer to the forklift standard as the pattern by which training should be carried out for other pieces of equipment. On a side note, OSHA is slowly but surely making training requirements specific for other pieces of equipment so there are no gray areas. Mobile cranes and aerial lifts, for instance, are all undergoing potential changes to the regulations that will reference training specifically.

So, with that in mind, we sayfront end loader operators must be re-evaluated every three years to determine if they are still competent enough to operate. We also state that this every-three-year front end loader evaluation is the maximum time that should be allowed to pass before an operator receives front end loader recertification. According to OSHA, there are several instances that will require additional front end loader training and observation before the three year period is up:

Front end loader operator is observed in an accident or a near miss
Front end loader operator received a poor evaluation or is observed driving in a dangerous manner
The front end loader operator is assigned to drive a different type of front end loader or the workplace has changed significantly enough to require additional front end loader training (such as being transferred from operating a front end loader used to hoist signs to a front end loader used for trimming trees).
I’ve received front end loader training. Can I operate a track loader or skid steer loader?
Not necessarily. OSHA requires operators to receive training for each type of loader. On this term, “type,” there is much confusion. Generally speaking, by “type” OSHA means skid steer vs. front end loader vs track loader or multi-terrain loader. But loader operations can vary widely by machine size and capacity. So different sized front end loaders—even within the same brand–could also qualify as different types.

If you have received front loader training and have always operated a rubber-tired CAT loader, but then are asked to operate a rubber-tired John Deere loader, 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, 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 front end loader and there was a front end loader accident and OSHA came to investigate only to discover that you had received training specific to skid steers but not front end loaders, then you’d be liable. You can’t really train too much.

I’ve operated loaders 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, OSHA requires front end loader training, a front end loader written exam, and a practical front end loader evaluation. There is no way around it. This goes for other types of loaders too. The extent of the classroom front-end loader 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 front-end loader operator not only understands but is capable of operating the machine safely.

I received front-end loader 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 OSHA that they trained you on safe front-end loader operations.

What is front-end loader certification? Who can train, evaluate, and certify operators?
This, above all, causes a lot of confusion. Bottom line, OSHA 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 front-end loader training kits on CD, USB or available via Digital Download or our online front-end loader safety training) OSHA does not recognize one company over another. They simply state that ‘training needs to occur’ and ‘here are the things a front loader operator should be trained on.’

When we do live or online front-end loader 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 front-end loader operation.

Do I have to wear a seat belt when operating a front-end 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 front-end loader does not have a seat belt, then the choice is yours. Technically, OSHA 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, OSHA will most likely fine you for not wearing it.

Do I have to wear a hard hat in a front-end loader?
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 OSHA 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 front loaders? 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 wheel loader practical evaluation if I take the training online?
The online wheel loader training class covers OSHA’s 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 front-end loader. When done, they can sign it and file it with your exam. This will satisfy OSHA’s requirements for front end loader certification.

My trainee scored 80% on the exam. Did he pass or fail?
Contrary to popular belief, OSHA 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 wheel loader. 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.