Many employers reach a point where bringing in an outside trainer for every new hire stops making sense. Turnover is steady, new operators start every few weeks, and someone on site already knows the trucks well. The answer is often an in-house forklift trainer, and the usual path there is a train-the-trainer course.
Before you pick someone and send them to a class, it helps to know what OSHA actually requires of a trainer. The rules are shorter than most people expect, and a few of OSHA's own interpretation letters settle the common questions.
What OSHA requires of a forklift trainer
OSHA's powered industrial truck standard, 29 CFR 1910.178, has one sentence on trainer qualifications:
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)(2)(iii))
That's it. The standard doesn't list a required course, a license or a number of years. It sets a performance test: the person has to know the material, be trained to teach it and have the experience to judge whether someone else is driving safely.
The same qualification applies to supervising trainees. Until they finish training, trainees may operate a truck only under the direct supervision of someone with that knowledge, training and experience, and only where it doesn't endanger the trainee or other employees (1910.178(l)(2)(i)).
What "experience" means
In a 2003 interpretation letter, OSHA explained that a trainer generally has enough experience only if they have "the practical skills and judgment to be able to himself operate the equipment safely under the conditions prevailing in the employer's workplace."
OSHA gave an example: if your trucks use certain attachments and the trainer has never run a truck with those attachments, the trainer doesn't have the experience to train and evaluate others on them.
The same letter says the trainer doesn't have to drive a forklift regularly as part of their job outside of training. What matters is that they can safely operate the equipment your operators use, in the conditions your operators work in.
Is a train-the-trainer course required?
No. In a 2000 interpretation letter about a manufacturer's train-the-trainer class, OSHA wrote: "There is no requirement that the trainer attend a train-the-trainer course. However, you may find it useful to have trainers attend such a course."
The same letter carries a warning. A general course run on an obstacle course, with trucks and conditions that don't match the attendee's workplace, helps people build their own training program. On its own, though, it isn't enough to count as operator training unless it covers the truck-related and workplace-related topics in 1910.178(l)(3). OSHA said it was unlikely a general course could cover all of those for every attendee's site.
So a train-the-trainer course is a practical way to give someone the "training" part of the qualification. The "experience" part has to match your trucks and your building.
Evaluations have to happen in person
In an April 2025 interpretation letter, OSHA was asked whether a qualified person could evaluate operators over a live video stream. OSHA's answer: direct supervision means the qualified person who is observing and evaluating operators is physically at the location where practical training and evaluation take place.
That matters for employers with several sites. A single trainer at headquarters can't evaluate operators at another plant over a video call. Each site needs a qualified person on the floor for practical training and evaluations. Our post on online forklift certification covers the same limit from the operator's side.
What your in-house trainer will be responsible for
Once someone is your trainer, they carry out the whole training program in 1910.178(l):
- Formal instruction, such as lecture, discussion, interactive computer learning, video or written material (1910.178(l)(2)(ii))
- Practical training, meaning demonstrations by the trainer and exercises by the trainee (1910.178(l)(2)(ii))
- Evaluation of each operator's performance in the workplace (1910.178(l)(2)(ii))
- Every truck-related and workplace-related topic in 1910.178(l)(3), unless the employer can show a topic doesn't apply. That includes vehicle capacity, stability, inspection, surface conditions, ramps, narrow aisles and pedestrian traffic.
- Refresher training after unsafe operation, an accident or near miss, a failed evaluation, a new type of truck or a change in the workplace (1910.178(l)(4)(ii))
- An evaluation of each operator at least once every three years (1910.178(l)(4)(iii))
The employer then certifies each operator. The certification must include the operator's name, the training date, the evaluation date and the identity of the person who did the training or evaluation (1910.178(l)(6)). Your trainer's name goes on every record, which is one more reason to pick someone whose qualifications you can explain.
Choosing the right person
OSHA doesn't set a profile, but the letters above point to a few practical questions:
- Can they safely run every truck and attachment your operators use? If not, they need that experience before they train on it.
- Do they know your building? Its ramps, docks, aisles, blind corners and loads are all part of the workplace topics they have to cover.
- Will they be on site for evaluations? Evaluations and practical training need the trainer physically present.
- Can they tell a trainee they're not ready? An evaluation only works if the evaluator is willing to fail someone.
- Can they teach in the language your operators understand best? Training has to actually get through to the operator.
It's also worth having more than one qualified person, so training doesn't stop when your trainer is on vacation or leaves.
How BHG Forklift Training helps
BHG offers forklift train-the-trainer for employers who want to run operator training in-house. We also train and evaluate operators directly at your facility, on your own trucks, across all seven OSHA truck classes, from Class 1 electric riders to Class 7 rough terrain forklifts. Training is available in English and Spanish.
Tell us about your trucks, your sites and who you want to train, and we'll talk through the right setup. For the operator side of the process, see how to get forklift certified.