{"id":799,"date":"2016-06-23T20:50:37","date_gmt":"2016-06-24T01:50:37","guid":{"rendered":"https:\/\/taocompliance.com\/?p=799"},"modified":"2016-06-23T20:16:54","modified_gmt":"2016-06-24T01:16:54","slug":"who-is-certified-qualified-to-train-process-operators","status":"publish","type":"post","link":"https:\/\/taocompliance.com\/?p=799","title":{"rendered":"Who is Certified \/ Qualified to Train Process Operators?"},"content":{"rendered":"

Variations of this question are a favorite of OSHA\/EPA inspectors and generally the question is infuriating. It reminds me of the stories of medieval monks arguing over how many angels can dance on the head of a pin \u2013 it\u2019s a question with ZERO relevance to the requirements of the PSM\/RMP standard. Why? Well, remember that PSM\/RMP is a Performance-Based Standard <\/em>and let\u2019s look at the requirements:<\/p>\n

First, we have Initial Training in 1910.119(g)(1)(i) which tells us what <\/strong>to provide training in and when <\/strong>to provide it:<\/p>\n

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Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.<\/p>\n<\/blockquote>\n

That\u2019s telling us we have to train people BEFORE they work on the process. Generally speaking, that\u2019s interpreted as before they start working on the process independently because it\u2019s assumed that shadowing already qualified operators is an accepted training method. It also tells us that they need to be trained in the hazards of the process, emergency operations, shutdowns and safe work processes that are applicable to the things they are going to be asked to do.<\/p>\n

So, if I am going to bring Suzy on board as an operator, I have to train her in the overall hazards of the process, how to operate it (including emergency operations), how to shut it down and in the safe work processes that she\u2019s going to be asked to perform. If I am asking her to clean a condenser sump, I have to have trained her in it. If I am NOT asking her to do that task, then I don\u2019t have to train her in it!<\/p>\n

Next, we have Refresher Training in 1910.119(g)(2) which again tells us what <\/strong>to provide training in and when <\/strong>to provide it:<\/p>\n

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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 employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.<\/p>\n<\/blockquote>\n

That\u2019s telling us that we have a performance burden <\/em>\u2013 \u201cto assure that the employee understands and adheres\u201d to the current operating procedures of the process. Let me be really honest here: If your employee understood the procedure at one point (assuming you haven\u2019t changed it) then they should understand it forever. Lacking the interference of hard drugs, brain injuries or Alzheimer\u2019s\u2019 you don\u2019t un-understand<\/em> something. What the issue is really is this: People ignore procedures. You have to make sure the practice in the field matches the practice in your written procedure.<\/p>\n

Ok, now we know what <\/strong>to provide training in and when <\/strong>to provide it. The question that is vexing us is: Who <\/strong>can provide the training? There is no clear answer to this, but there is a very defensible <\/em>answer to this and it is based on the documentation requirements in 1910.119(g)(3):<\/p>\n

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The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.<\/p>\n<\/blockquote>\n

You see that bit at the end: \u201c\u2026the means used to verify that the employee understood the training?\u201d That\u2019s a performance burden, <\/em>and if you couple that with the 1910.119(g)(2) performance burden<\/em>, you get this:<\/p>\n

Do your employees understand the training you provided so that they:<\/p>\n