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 – it’s a question with ZERO relevance to the requirements of the PSM/RMP standard. Why? Well, remember that PSM/RMP is a Performance-Based Standard and let’s look at the requirements:
First, we have Initial Training in 1910.119(g)(1)(i) which tells us what to provide training in and when to provide it:
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.
That’s telling us we have to train people BEFORE they work on the process. Generally speaking, that’s interpreted as before they start working on the process independently because it’s 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.
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’s 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’t have to train her in it!
Next, we have Refresher Training in 1910.119(g)(2) which again tells us what to provide training in and when to provide it:
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.
That’s telling us that we have a performance burden – “to assure that the employee understands and adheres” 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’t changed it) then they should understand it forever. Lacking the interference of hard drugs, brain injuries or Alzheimer’s’ you don’t un-understand 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.
Ok, now we know what to provide training in and when to provide it. The question that is vexing us is: Who can provide the training? There is no clear answer to this, but there is a very defensible answer to this and it is based on the documentation requirements in 1910.119(g)(3):
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.
You see that bit at the end: “…the means used to verify that the employee understood the training?” That’s a performance burden, and if you couple that with the 1910.119(g)(2) performance burden, you get this:
Do your employees understand the training you provided so that they:
- Understand the process
- Understand the procedures
- Follow the procedures
Ask yourself a question: If you were training an employee in draining an oil pot, how would you know that your training was successful?
In the real world, we know a trainee understands the procedures and follows them by observing them performing the task. You provide the training. You go through the procedure with them. Maybe you have them observe you doing the task. At some point, you’re going to have them perform the task and observe that they follow the procedure.
Some people get caught up in the HOW when it comes to training. What I described above is, in my opinion, the best way to train an operator in the real world. But, honestly, the HOW isn’t important – what’s important is the results of the training. If you bring in an MIT professor to teach thermodynamics, or a group of traveling circus midgets who “teach” thermodynamics through the power of interpretive dance, the ONLY acceptable real-world criteria for judging the qualifications of those trainers is the results of the training.
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Note: Yes, it’s easier to defend the use of a college professor teaching the material – or for that matter a RETA RAI or CIRO than someone without qualifications. That said, at some point the argument becomes futile: Who certified those people and what makes them qualified? If you follow that trail far enough you end up at the same place. At some point, someone did the job well enough and often enough that the people around them said: This guy knows his stuff. Qualification is in the doing. Ultimately being able to do the job is the only defensible argument that you were trained in it and, frankly, the only one that really matters.
