Forklift Operator Training When You Switch to Lithium-Ion

Does a lithium-ion conversion trigger refresher training?

Our position is yes, and the regulation gives you two separate hooks to hang it on. 8 CCR 3668(d) lists the circumstances that require refresher training, and two of them apply directly:

"Refresher training in relevant topics shall be provided to the operator when: (A) The operator has been observed to operate the vehicle in an unsafe manner; (B) The operator has been involved in an accident or near-miss incident; (C) The operator has received an evaluation that reveals that the operator is not operating the truck safely; (D) The operator is assigned to drive a different type of truck; or (E) A condition in the workplace changes in a manner that could affect safe operation of the truck."

A conversion from lead acid to lithium-ion usually satisfies (D), because the trucks themselves are replaced or re-powered. It satisfies (E) regardless, because the charging procedure, the hazards present at the charging area and the correct emergency response all change on the day the new packs arrive.

To be straight with you: Cal/OSHA has not published a determination that a chemistry change on its own is a triggering condition. We asked Consultation that exact question in writing on 10 September 2026 and we will publish the answer here when it arrives. Until then this is our reading, and it is the conservative one.

What does the training actually have to cover?

8 CCR 3668(c) splits the required content into truck-related topics and workplace-related topics. The conversion changes items on both sides of that split.

Truck related. Operating instructions and warnings for the truck the operator will drive, differences between the truck and an automobile, controls and instrumentation, engine or motor operation, steering and maneuvering, visibility, capacity and stability, and battery charging and recharging procedures for that truck. A lithium pack charges differently, opportunity charges where a flooded pack could not, and has no watering routine at all.

Workplace related. Surface conditions, load composition and stability, pedestrian traffic, narrow aisles and restricted places, hazardous locations, ramps and sloped surfaces, and other conditions that could affect safe operation. The charging area is a workplace condition. If it moved indoors, or if the ventilation and spill controls that served a flooded battery room are no longer the right controls, that is a change the operator needs to be trained on.

What has to be in the record?

This is where most programs come apart, because the training happens and the paperwork does not.

8 CCR 3668(f) requires the employer to certify that each operator has been trained and evaluated, and the certification has to include the name of the operator, the date of the training, the date of the evaluation and the identity of the person or persons performing the training or evaluation.

8 CCR 3668(d) also sets the standing interval: "An evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years." A refresher triggered by the conversion does not replace that clock, and the three year evaluation does not substitute for the conversion refresher. They are separate obligations and the record should show both.

8 CCR 3668(e) does let you skip duplicative training where an operator has already been trained and evaluated on the relevant topics and the employer determines they remain competent. Note what that requires: a determination, made by you, on the record. It is not a default.

Is there anything in the federal standard about lithium?

No. 29 CFR 1910.178, the federal powered industrial truck standard, contains no occurrence of lithium, lithium-ion or thermal runaway anywhere in its text. Paragraph (a)(2) still incorporates ANSI B56.1-1969 by reference. The lithium-ion cell was commercialized in 1991.

That absence is the reason this page exists. The equipment standard will not tell your operator what to do with the new battery, so the training standard and your own written program have to carry it. We set that out in full in our brief on the lithium-ion forklift compliance gap.

What we add to the training when a client converts

Four things, and they are the four the equipment standard does not supply.

  1. The warning signs, taught as the trigger. Unusual smell, heat, a change in shape or geometry, abnormal behavior, a leak or an odd noise. Operators are taught to stop, park the truck away from anything that can catch fire if that can be done safely, and report. Not to investigate.
  2. What the extinguisher on the wall is for. Since 28 August 2026 California's own position is that no listed extinguisher exists for putting a lithium-ion battery out. Operators should know the extinguisher is there to keep fire off what surrounds the battery, so nobody stands in front of a venting pack believing the cylinder in their hands will end it.
  3. The charging procedure for that specific pack, from the manufacturer document, attached to the program. Not generic lithium guidance.
  4. Who calls 911, and what they say. Naming the battery chemistry and the approximate capacity on that call changes what rolls out of the station.

How this page was verified

Section 3668 was read in full on the Department of Industrial Relations site on 11 September 2026 and the quotations above are verbatim from it, including the complete list of refresher triggers and the evaluation interval. 29 CFR 1910.178 was searched for lithium, lithium-ion and thermal runaway, none of which appear in it. Where we state a position rather than a requirement, we label it as our position.

Every regulation quoted on this page was read in the original on the Department of Industrial Relations site or in the source document, not recalled. Where a question has no settled answer we say so rather than inventing one.

Who wrote this

M Squared Safety Solutions, Inc. is a California occupational safety consultancy and training provider in San Clemente. This page was written by Matthew Horovitz, Competent Person and former OSHA 500 authorized construction outreach trainer, with 20 years in risk management. It is free to read and free to quote with attribution.

What we do about this. We write the plan language for the specific pack on your site, record the determination where the published sources conflict, and train the people who will be standing there. Call 949-954-6581 or book a call.

Related guides

Primary sources

This page describes what the standards say. It is not a safety program, and whether any procedure is right for a particular job site and a particular battery is a determination for that employer, its own competent person, the equipment manufacturer and the authority having jurisdiction.