Training Spanish-Speaking Forklift Operators: What OSHA Requires

Your crew speaks Spanish and your trainer speaks English. Here is what OSHA expects, what an inspector checks, and a practical way to cover the classroom, the hands-on training, and the evaluation.

The short answer

OSHA's policy is that required training must be given in a language and vocabulary the worker can understand. For a Spanish-speaking forklift operator, that means the classroom instruction, the hands-on practice, and the evaluation all have to reach them in Spanish, or in another language they understand. English-only training for a worker who does not understand English does not meet the forklift standard, 29 CFR 1910.178(l), even if the paperwork is complete.

Does OSHA require forklift training in a language workers understand?

Yes. The forklift standard itself does not mention language, but OSHA applies one policy to all of its training requirements. It is set out in the April 28, 2010 memorandum "OSHA Training Standards Policy Statement," from the Assistant Secretary to OSHA's regional administrators. The memo says the policy "applies to all of the agency's agriculture, construction, general industry, and maritime training requirements," which includes forklift operator training. The key passage:

"In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand."

The memo also gives employers a rule of thumb. If you customarily give work instructions in a language other than English, you "will also need to provide safety and health training to employees in the same manner." If your supervisors already run the shift in Spanish, forklift training belongs in Spanish too.

Read the full memo on osha.gov. For the rest of what the forklift rule requires, see our guide to OSHA forklift certification requirements.

What does an OSHA inspector check?

Whether the operators actually understood their training, not only whether you have records. The 2010 memo tells compliance officers that they "must check and verify that the training was provided in a format that the workers being trained could understand." It also tells them to "look beyond any basic paper documentation," because an employer "may have training records but employees may not have been able to understand the elements included in the training."

One of the things the memo tells inspectors to look at is the language you already use on the floor: whether "workplace instructions regarding job duties are given in a language other than English."

If a reasonable person would conclude the training was not conveyed in a way employees could understand, the memo says the violation "may be cited as serious" when it fits OSHA's usual enforcement guidelines. In practice, a signed English sign-off sheet from an operator who cannot read English is weak evidence of training.

What if an operator has limited vocabulary or does not read well?

Then reading material alone is not enough. The same memo says: "if the employee's vocabulary is limited, the training must account for that limitation," and "if employees are not literate, telling them to read training materials will not satisfy the employer's training obligation."

That applies to any written course, ours included. Our Spanish course is read on screen, with pictures. For an operator who reads Spanish comfortably, that works. For one who does not, plan on a Spanish-speaking trainer walking through the material out loud, and lean harder on demonstration and practice on the truck.

How do you cover each part of forklift training in Spanish?

Forklift training has three required parts under 29 CFR 1910.178(l)(2)(ii): formal instruction, practical training, and an evaluation of the operator's performance in the workplace. Each one has to reach the operator in a language they understand.

Part What the rule says How to do it for a Spanish speaker
Formal instruction Lecture, discussion, interactive computer learning, video, or written material A course in Spanish, or a Spanish-speaking instructor. Add your own site rules in Spanish: routes, speed limits, pedestrian areas, charging or refueling spots.
Practical training Demonstrations by the trainer and exercises by the trainee A bilingual trainer, or a qualified trainer working with an interpreter who knows the equipment.
Evaluation The operator's performance in the workplace Give instructions and ask questions in Spanish. Have the operator explain back, in Spanish, what they are checking and why.

The workplace topics in 29 CFR 1910.178(l)(3)(ii) are easy to miss here. Surface conditions, pedestrian traffic, narrow aisles, ramps, and closed areas where carbon monoxide can build up are specific to your building, so no off-the-shelf course can cover your version of them. Explain them in Spanish on the floor.

Our free forklift operator evaluation form gives the evaluator a checklist to work from, and our forklift training program guide lays out who trains, who evaluates, and what to keep on file.

My forklift trainer only speaks English. What are my options?

Any of three setups can work, as long as the person running the training and the evaluation is qualified. 29 CFR 1910.178(l)(2)(iii) requires that all operator training and evaluation be conducted by people "who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence." The forklift standard says nothing about interpreters, so the three options below are our practical reading of the rule and the 2010 memo, not OSHA wording.

  • Make a bilingual employee the trainer. A supervisor or lead operator who speaks both languages and knows your trucks can run the practical training and evaluation directly. Our Train the Trainer course ($299) prepares them for that role. It is taught in English, so it fits a bilingual trainer, not a Spanish-only one. See also our guide to forklift trainer requirements.
  • Keep your English-speaking trainer and add an interpreter. The trainer stays responsible for the training and the evaluation. Pick an interpreter who knows forklift words (mast, forks, load center, tilt) and your site, and have them interpret both ways, so the operator's questions reach the trainer too.
  • Hire an outside trainer who teaches in Spanish. OSHA allows outside trainers. The employer still certifies each operator and stays responsible for the result.

Whichever you choose, check understanding before you sign anything off. An operator who can walk you through a pre-shift inspection in their own words understood it. One who nods along may not have.

What should the certification record show?

The same four items as for any operator. Under 29 CFR 1910.178(l)(6), the employer certifies that each operator has been trained and evaluated, and the certification must include the operator's name, the date of the training, the date of the evaluation, and the identity of the person or people who performed the training or evaluation.

The rule sets no language for the record, and OSHA does not require you to note the training language. We suggest noting it anyway. Because inspectors are told to check whether workers understood, a line such as "training and evaluation conducted in Spanish" answers the question before it is asked. Our forklift certification card guide covers what the record and wallet card should show.

How our course handles Spanish-speaking operators

Spanish is included at no extra cost. Every operator enrollment, individual ($59) or team seat, includes the full course in both English and Spanish, and the operator can switch languages at any point. The 30-question final exam is in Spanish too, with 80% to pass and unlimited free retakes.

  • Mixed crews on one order. Team seats include both the English and Spanish courses in every seat, so you do not buy separate versions. You add each operator from the team dashboard, and each one picks the language that works for them. Seats cost $50 each for 2 to 4 operators, $40 for 5 to 9, and $30 for 10 or more.
  • English paperwork. The certificate and wallet card are issued in English, which is what US employers and inspectors read, and the certificate states that the training was taken in Spanish.
  • English checkout. The checkout page and team dashboard are in English. Operators can read about the course in Spanish on our certificación de montacargas page, and we have Spanish guides to tipos de montacargas and accidentes con montacargas.

What the course does not do: it covers the formal instruction only. OSHA also requires practical training and a hands-on evaluation by the employer before an operator is certified (29 CFR 1910.178(l)(2)(ii) and (l)(6)). Those parts still have to happen on your trucks, at your site, in Spanish.

Free OSHA forklift materials in Spanish

Two free government handouts are useful for toolbox talks and for posting near the charging or parking area:

Frequently asked questions

Is forklift training required to be in Spanish?
It is required to be in a language the operator understands. OSHA's 2010 Training Standards Policy Statement says that if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. For an operator whose working language is Spanish, that means Spanish.
Can a bilingual coworker translate during forklift training?
The forklift standard does not mention interpreters. What matters under OSHA's 2010 policy is whether the operator understood the training. A bilingual coworker who knows the equipment and the site can make that happen. The coworker does not replace the qualified trainer and evaluator required by 29 CFR 1910.178(l)(2)(iii), unless they have the knowledge, training, and experience to be one.
Does the forklift certification record have to be in Spanish?
No. 29 CFR 1910.178(l)(6) lists what the certification must include: the operator's name, the date of training, the date of evaluation, and who performed the training or evaluation. It sets no language. Our certificate is issued in English and states when the training was taken in Spanish.
Is there an OSHA forklift test in Spanish?
OSHA does not give a forklift test or issue operator certificates. The employer certifies each operator after training and evaluation. Our Spanish course ends with a 30-question exam in Spanish, 80% to pass, with free retakes.
Do refresher training and the 3-year evaluation also need to be in Spanish?
Yes. The language policy covers every OSHA training requirement, so refresher training under 29 CFR 1910.178(l)(4)(ii) and the evaluation required at least every three years under (l)(4)(iii) have to reach the operator in a language they understand, the same as the first round.
Do workers have a right to safety training in their own language?
OSHA lists it among workers' rights: to "Receive workplace safety and health training in a language you understand." The employer carries the duty to deliver it.

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