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A Forklift Runs on Four Clocks. None of Them Is in Your Diary.

A forklift in a South African workplace carries at least four legal clocks, and a crane carries the same four
September 28, 2026 by
Philip de Witt
12 min read

In brief

A forklift in a South African workplace carries at least four legal clocks, and a crane carries the same four. The machine itself must be thoroughly examined and performance tested by a registered lifting machinery inspector at intervals not exceeding 12 months. [1] Its ropes, chains, hooks, sheaves, brakes and safety devices must be thoroughly examined at intervals not exceeding six months. [1] The slings, chains and shackles used with it must be examined at intervals not exceeding three months by a competent person appointed in writing. [1] And the person driving it must hold a certificate of training from an accredited provider, backed by a carry card that is valid for up to 24 months. [1][2] None of those dates is set by a gazette. Each one starts on the day the employer's own last examination, test or course happened, so no national calendar and no annual audit resets them. When the Department of Employment and Labour inspected an aluminium manufacturer in Thaba Nchu in June 2026, "forklift operators lacking competency certification" was on the list of contraventions that drew prohibition notices. [3] When a joint operation visited a steel manufacturer in Ekurhuleni in September 2026, the reported outcome included a crane taken out of use until repaired and forklifts stopped because their operators were not trained or licensed. [4] Neither finding was about an obscure rule. Both were about a date.

What the regulations actually require

The duties sit in regulation 18 of the Driven Machinery Regulations, 2015, made under section 43 of the Occupational Health and Safety Act and in force since 30 September 2015. [1] They apply to the "user" of a lifting machine, which in almost every SME is the employer. Read at clause level, regulation 18 creates five separate obligations, and four of them are clocks.

The machine. Regulation 18(5)(a) requires the entire installation and all working parts of every lifting machine, and the ancillary lifting equipment used with it, to be subjected to a thorough examination and a performance test by a lifting machinery inspector of a lifting machinery entity. That must happen before the machine is put into use, every time it is dismantled and re-erected, "and thereafter at intervals not exceeding 12 months". [1] Where the manufacturer's standard prescribes no performance test, the whole installation is tested at 110 percent of the safe working load across its complete lifting range. [1] A lifting machinery inspector is a person employed by an entity approved by the Chief Inspector and registered with the Engineering Council of South Africa, so this is not a test a competent employee can do in house. [1] Mobile cranes, self-erecting cranes and mobile elevated work platforms are excused a fresh performance test after each redeployment within the 12-month period, but not the annual one. [1]

The parts that wear. Regulation 18(6) adds a shorter clock for the components that fail first: all ropes, chains, hooks or other attaching devices, sheaves, brakes and safety devices forming an integral part of the machine must be thoroughly examined by a competent person "at intervals not exceeding six months". [1]

The tackle. Regulation 18(10)(e) puts the shortest clock on the loose gear used with the machine: lifting tackle must be examined "at intervals not exceeding three months by a competent person, appointed by the user in writing for this purpose, who shall record and sign results of such examination". [1] That is two documents, not one: the written appointment, and the signed record of each examination.

The operator. Regulation 18(11) requires every lifting machine to be operated by an operator specifically trained for that type of machine, and for machines listed in the National Code of Practice for Training Providers of Lifting Machine Operators it goes further: the user "shall not require or permit any person to operate such a lifting machine unless the operator is in possession of a certificate of training" from a provider accredited by the Transport Education and Training Authority and approved by the Chief Inspector. [1] The listed machines are primarily lift trucks and cranes, and the list is long: counterbalanced, reach, pedestrian-controlled and order-picker lift trucks, battery-powered pallet trucks, overhead cranes, truck-mounted cranes, telescopic handlers, mobile elevated work platforms, and hoists and winches among them. [2]

The register. Regulation 18(7)(a) requires the user to keep, on the premises at all times, a register recording full particulars of every examination and performance test under subregulations (5) and (6), and every modification or repair, and to make it available to an inspector on request. [1] That requirement is what turns the four clocks into evidence, and its absence is what turns a sound machine into a finding.

The operator's clock is the one that runs out quietly

The Code of Practice sets out how the operator's certification works in practice, and it contains the detail most employers have never read. [2]

A carry card "will be valid for a period of up to 24 months", and it is issued on certification and on every re-certification. [2] The Code states in terms that no person shall operate any equipment it covers "without a valid certificate of competence and a carry card". [2] Re-certification before expiry is short: a minimum of four hours of theory with a focus on safety and one hour of practical training and assessment. [2] But where the carry card has been expired for more than 90 days, the operator "has to undergo novice training", which is the full initial course again. [2]

That 90-day line is where the cost sits. An operator whose card lapsed in March and who is booked for a refresher in August is no longer eligible for the refresher. The employer who notices in month four pays for the full course and loses the operator from the machine for its duration. The employer who does not notice is, from the day of expiry, permitting an uncertificated person to operate a listed lifting machine, which regulation 18(11) prohibits.

It also compounds. The certificate is issued per machine code, and an upgrade to a different type of machine, or a new attachment, requires further training and assessment. [2] An operator certified on a counterbalanced truck is not certified on a reach truck because the two look similar. A business that bought a second, different machine last year may have operators who are properly certified on one of them.

Why the dates escape the file

Put the four clocks next to each other for a modest operation: two forklifts, one overhead crane, and five people who drive them.

  • Three machines, each with a 12-month examination and performance test date.
  • Three machines, each with a six-month examination of integral components.
  • The slings, chains and shackles in use, on a three-month examination cycle signed by a person appointed in writing.
  • Five operators, each with a certificate per machine code and a carry card with its own expiry.

That is at least eleven live dates for a small site, before counting tackle item by item, and not one of them was set by a gazette. Each started on the day of the employer's own last event: the day the inspector came, the day the course ended, the day the sling was checked. So they drift apart from one another, and from the financial year, immediately.

They also live in four different places. The lifting machinery inspector's certificate arrives by email from the entity that did the test. The six-monthly and three-monthly records sit in a register or on a clipboard near the machine. The carry card is in the operator's wallet. And where the machine is hired, regulation 18(7)(b) requires the user to hold on its own premises the latest performance test and service records, not older than 12 months, which means documents that belong to the hire company have to be in the user's file. [1] Nothing about any of that is unusual or careless. It is simply what the regulation produces when it is run by hand.

The consequence is exposure to the least forgiving instrument an inspector carries. The Department's June 2026 statement records that the Thaba Nchu contraventions, the forklift competency finding among them, were met with prohibition notices "to prevent further exposure of workers to dangerous conditions until compliance is achieved". [3] A prohibition notice does not wait for a court. It stops the machine, and in a warehouse or a fabrication shop, stopping the forklift stops the business.

What the record shows

The two findings above are worth reading carefully, because they carry different weights of evidence and we have kept them apart.

Thaba Nchu, 10 June 2026. The Department's own statement, published 12 June 2026, lists "Forklift operators lacking competency certification" among the occupational health and safety contraventions found at an aluminium manufacturer, alongside missing emergency exits, unguarded machinery and electrical installations not properly labelled or earthed, and records that prohibition notices were issued. [3] This is a primary source.

Ekurhuleni, 22 September 2026. A joint operation by the Department of Employment and Labour, Home Affairs, the South African Police Service and the City of Ekurhuleni visited a steel manufacturer. That the operation took place, and that officials said workers had been told not to report for duty after word of it got out, is reported by three independent outlets. [4][5][6] The lifting findings, a damaged crane taken out of use until repaired and forklifts stopped because the operators were "not trained" and "not licensed", together with concerns about electrical installation compliance, are reported by one outlet quoting the Deputy Minister, and we treat them as provisional until a second source or a departmental statement confirms them. [4] No departmental statement on this operation had been published when this article was written.

What the two have in common is the point. In both, the lifting equipment finding sat next to an electrical finding and a guarding or maintenance finding: the ordinary, dated, recurring items. [3][4] We do not name either employer.

What evidence of compliance looks like

If an inspector asked for it this afternoon, this is what a compliant user of lifting machinery would be able to produce from the premises, without phoning anyone.

  • For each lifting machine, the most recent thorough examination and performance test by a lifting machinery inspector, dated within the last 12 months, with the entity's details. [1]
  • For each machine, the six-monthly examination record of ropes, chains, hooks, sheaves, brakes and safety devices. [1]
  • The written appointment of the competent person who examines lifting tackle, and that person's signed three-monthly records. [1]
  • For each operator, a certificate of training for each machine code they operate, and a carry card that has not expired. [1][2]
  • For any hired machine, the hire company's latest performance test and service records, not older than 12 months, held on your premises. [1]
  • The register under regulation 18(7)(a), recording every examination, test, modification and repair. [1]

The test of whether this is under control is not whether each document exists. It is whether anyone in the business can say, today, which of those dates falls next, and whose it is.

GRC Shop view

Everything in this section is our opinion.

Lifting equipment is the clearest illustration we know of a compliance duty that good people get right and a good file still loses. The lifting machinery inspector who tested the crane in March was right in March. The training provider who certified the operator two years ago was right two years ago. The auditor who saw a current certificate on the day of the audit was right that day. Nobody in that chain was careless, and nobody in it owns the next date, because the next date is not on anyone's invoice.

That is why we think lifting findings will keep appearing on blitz reports long after the rules are well known. They are not knowledge failures. They are the gap between a correct document and a current one, multiplied across machines, components, tackle and people, with each clock set by the employer's own last event rather than by a date the whole country shares.

The audit is fine. What fails is afterwards, because closing items out happens in email while the evidence scatters, so the certificate is in someone's inbox, the tackle register is on a clipboard and the carry card is in a wallet, and a year later the report still reads clean while the file no longer matches the site. That is not neglect. It is that nothing holds the pieces together between audits, and the 90-day line on a carry card is short enough to fall entirely inside that gap.

Compliance files go stale. Our system keeps yours current. If you want every machine, component, tackle cycle and operator card held as one dated record rather than four piles: https://www.grcshop.co.za/get-a-quote

Abbreviations

  • DMR: Driven Machinery Regulations, 2015
  • ECSA: Engineering Council of South Africa
  • LMI: lifting machinery inspector
  • OHS: occupational health and safety
  • OHS Act: Occupational Health and Safety Act 85 of 1993
  • SME: small and medium enterprise
  • TETA: Transport Education and Training Authority

References

[1] Republic of South Africa, "Driven Machinery Regulations, 2015", Government Notice R540, Government Gazette 38905, 24 Jun 2015, consolidated text, regulation 18. https://www.saflii.org/za/legis/consol_reg/dmr2015283/index.html

[2] Department of Labour, "National Code of Practice for Training Providers of Lifting Machine Operators", Government Notice R539, Government Gazette 38904, 24 Jun 2015. https://natlex.ilo.org/dyn/natlex2/natlex2/files/download/100407/ZAF100407.pdf

[3] Department of Employment and Labour, "Deputy Minister Jomo Sibiya Leads High-Impact Blitz Inspections in Thaba Nchu, Uncovers", 12 Jun 2026. https://www.labour.gov.za/Media-Desk/Media-Statements/Pages/Department-of-Employment-and-Labour-Deputy-Minister-Jomo-Sibiya-Leads-High-Impact-Blitz-Inspections-in-Thaba-Nchu,-Uncovers.aspx

[4] IOL, "Steel manufacturing company faces scrutiny over alleged undocumented workers and safety breaches", 22 Sep 2026. https://iol.co.za/news/south-africa/2026-09-22-steel-manufacturing-company-faces-scrutiny-over-alleged-undocumented-workers-and-safety-breaches/

[5] TimesLIVE, "Deputy-minister's 'tip-off' leads to labour raid on steel company", 22 Sep 2026. https://www.timeslive.co.za/news/south-africa/2026-09-22-deputy-ministers-tip-off-leads-to-labour-raid-on-steel-company/

[6] SABC News, "Labour officials conduct raid at a steel manufacturing company", 22 Sep 2026. https://www.sabcnews.com/sabcnews/labour-officials-conduct-raid-at-a-steel-manufacturing-company/

[7] Toco Lifting, "DMR 18 Explained: Lifting Equipment Compliance in South Africa", 24 May 2026, updated 26 Sep 2026. https://tocolifting.co.za/lifting-guides/dmr-18-explained-lifting-equipment-compliance-south-africa/

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