Why is agriculture on a different training cycle than general industry/construction?

California’s Title 8 §3668 (Powered Industrial Truck regulation) contains an exception clause near the end: “Exception: Agricultural operations as defined in Section 3437 of the General Industry Safety Orders are exempt from the requirements of Section 3668.” That single sentence is the reason the cycles differ.

What are the training requirements under General Industry / Construction (§3668)?

  • Initial training and evaluation must occur before solo operation.
  • It involves a combination of formal instruction, practical training, and workplace evaluation.
  • “An evaluation of each powered industrial truck operator’s performance shall be conducted at least once every three years.”

Is refresher training optional in General Industry/Construction?

No, refresher training (interim) is required — not optional — when:

  • The operator is observed operating unsafely
  • The operator is involved in an accident or near-miss
  • The operator receives an unsafe evaluation
  • The operator is assigned to a different type of truck
  • The workplace changes in a way that affects safe operation

What are the training requirements for Agriculture (§3441 and §3664)?

  • §3441(a)(1): “At the time of initial assignment and at least annually thereafter, the employer shall instruct every employee in the safe operation and servicing of all equipment…”
  • §3664(b): Every employee who operates an agricultural or industrial tractor shall be instructed at initial assignment and at least annually thereafter.

What's a simple comparison of the two cycles?

  • Agriculture (AG): Annual
  • General Industry/Construction (GI): 3-year evaluation cycle

What governs training for MEWPs (scissor lifts, boom lifts)?

MEWP operator training is governed by ANSI/SAIA A92.22 (safe use) and A92.24 (training), supported by Cal/OSHA aerial-device sections.

Does ANSI specify a strict refresher cycle for MEWPs?

ANSI does not name a strict refresher cycle, but industry best practice — and what most insurers and GCs (General Contractors) require — is a 3-year operator re-evaluation, sooner if there’s an incident, equipment change, or supervisor concern.

What should be done if an operator works with both PIT and MEWP equipment?

Pair MEWP recerts with PIT recerts where the operator works both — meaning their re-evaluation schedules should be aligned so both are covered in the same cycle.