Many people struggle with Refresher Training. I think this is because the way they train to meet the PSM/RMP requirement is fundamentally flawed: Most places re-train each operator on EVERY SOP they are expected to perform at least every three years. I don’t think this has any benefit at all – it’s a waste of time and resources to do completely so most facilities just hand their operators a stack of SOPs and have them initial them. This “sign here” approach is not acceptable to OSHA and shouldn’t be acceptable to anyone else. So, let’s say we’re properly employing this approach and teaching each SOP (and each phase of those SOPs) to every operator at least every three years. To me this is an awful waste of time without much, if any, benefit to the operator.
Even worse, it isn’t what the standard requires:
1910.119(g)(2) Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process…
The key phrase here is “understands and adheres to the current operating procedures of the process.” Let me outline a simpler approach:
We’ll assume you initially trained each operator to follow the SOP and trained them in the SOP to the level that they understand it. You’ve also documented this training including the means you used to verify that the operator understood it. We’ll also assume you have a good MOC procedure so when the SOPs are updated, appropriate training is conducted so everyone understands the changes.
At this point in our scenario the operators understand the SOP. It’s unlikely they’ll suddenly stop understanding it, so our real issue now is how do we assure that they “adhere” to the current operating procedures of the process? Why not set up a system where we:
- Train annually to reinforce the importance of adhering to the written SOP and require a copy of the written SOP to be with an operator when they are performing a task.
- Set up a committee of operators to review each and every SOP for accuracy and efficacy at least every 2-3 years. Offer concrete ways that operators can make suggestions for improvements to the SOPs to this committee. (Think of the value here for documentation in your Employee Participation binder!)
- Occasionally audit operators on their adherence to the written SOPs – at a frequency that ensures every operator is observed for adherence to an SOP at least once a quarter. (Which SOP doesn’t really matter – we’re trying to ascertain they are adhering to the idea of written SOPs)
When we find that operators are adhering to the written SOP we have met our performance burden with the annual training on adhering to the written SOP.
When we find an operator who does not follow the written SOP, we initiate re-training on the importance of adhering to the written SOP and ensure that the reason they aren’t following it is because they never understood it to begin with.
Doesn’t this system seem a little bit better than the “way it’s always been done?”
