Forklift Certification for Temp and Staffing Agency Workers: Who Certifies?
When a staffing agency sends a forklift operator, both the agency and the host employer are responsible for training, and the host must evaluate the operator on its own trucks. What OSHA’s Temporary Worker Initiative bulletin says, and a practical split that works.
Both the staffing agency and the host employer are responsible for a temporary forklift operator’s training, and the host employer must evaluate each operator on its own equipment before they drive. That is OSHA’s position in Temporary Worker Initiative Bulletin No. 7, Powered Industrial Truck Training: the agency generally handles the generic formal instruction, the host provides site-specific training and the workplace evaluation, and neither can contract away its duty under the OSH Act.
What the Bulletin Says
- Shared duty. Both employers must ensure the operator is trained under 29 CFR 1910.178(l); the contract can divide the work, but “neither employer may avoid its ultimate responsibilities under the OSH Act by requiring another party to perform them.”
- Agency: generic training. The staffing agency is usually best placed to provide the general formal instruction and should take reasonable steps to confirm the host’s program covers the site’s hazards.
- Host: site-specific training and evaluation. The host knows the trucks and the site, so it provides the site-specific training and must conduct a workplace evaluation of each operator the agency supplies, even one who arrives already trained. The scope can be reduced for an experienced operator, but not skipped.
- Records. Whoever keeps the record, the host must know where it is and be able to produce it for an inspector. The bulletin recommends both parties share records, and both must track the three-year re-evaluation.
A Split That Works in Practice
| Step | Staffing agency | Host employer |
|---|---|---|
| Formal instruction (online or classroom) | Provides it before placement; sends the certificate with the worker | Confirms it covers 1910.178(l)(3) topics; may re-run it for a new truck class |
| Site-specific training | Confirms the host has a program | Walks the operator through the site: aisles, docks, pedestrian zones, charging area, specific trucks |
| Practical evaluation | Keeps a copy of the result | Evaluates the operator on the host’s trucks before unsupervised operation; records date and evaluator |
| Certification record (four items) | Holds the training date and provider | Holds the evaluation date and evaluator; both sides know where the full record is |
| Re-evaluation | Tracks the three-year date across placements | Re-evaluates on any new truck type, after incidents, and at three years |
Common Mistakes
- The host assumes the agency’s card means the operator can start. The host still owes a site evaluation; a card from anyone, including Shield, is the formal instruction only.
- The agency assumes the host will train from scratch. If the host’s program is thin, the agency has a duty to notice and address it.
- Nobody can find the record. An inspector will ask the host for the operator’s certification; “the agency has it” is only an answer if you can produce it that day.
- The three-year clock is lost between placements. The agency is the natural owner of that date because it follows the worker.
How Shield Fits
Staffing agencies buy seats and assign the course to operators before placement; the certificate and QR wallet card travel with the worker, and any host can verify it. Host employers run the practical evaluation with the included checklist (a general template to adapt to your site) and record it, so the four required items end up in one place. Either party can hold the dashboard record; both can see the certificate.
Forklift practical evaluation checklist (printable)
Frequently asked questions
Who certifies a temp forklift operator, the agency or the host?
Both share the duty. OSHA’s Temporary Worker Initiative Bulletin No. 7 says the agency generally provides generic training and the host provides site-specific training and must evaluate each operator on its own trucks.
Does a host employer have to evaluate an operator who arrives already certified?
Yes. The scope can be reduced for an experienced operator, but a workplace evaluation on the host’s equipment is still required before unsupervised operation.
Who keeps the forklift certification record for a temp?
Either party may hold it, but the host must know where it is and produce it for an inspector; OSHA recommends both share the record.
Sources: OSHA Temporary Worker Initiative Bulletin No. 7, Powered Industrial Truck Training (OSHA 3889); OSHA 29 CFR 1910.178(l), Operator training; OSHA: Powered industrial trucks, training and certification