Most companies will go to some degree of lengths in selecting “qualified” contractors to include things such as job examples, a list of qualifications, require subscription to the ISN network, etc. Even then, though, sometimes bad apples slip through the cracks if the company needing a “qualified” contractor doesn’t develop a scope or set of expectations for said contractor. But what about who performs your operator and PSM training? There are certainly some good trainers out there, but do you look beyond the advertisements? Have the instructor (s) of this organization ever personally operated an industrial ammonia refrigeration system, OR have they implemented and managed a PSM program with any degree of success?
This recently came up as a colleague called to ask who I would recommend performing their operator training. That question alone tells me a lot about their understanding of what the regulation actually requires of operator training. My response to her was, “Can I take a look at your operating procedures?” Confused, she asks why I need to see those to recommend a trainer. I continue, “Is it your understanding that this trainer will teach and certify your operators?” She responds with the typical yes. Then I read the regulation to her (paraphrasing) “the employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.” I then go back and show where the initial requirements are broken down into three (3) things;
- Shall be trained in an overview of the process (which is where these schools come into play. The operator knows basic theory and principles of ammonia refrigeration, but nothing plant-specific.
- In the operating procedures as specified….
- 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.
So, what I’m after is to quickly evaluate if your operating procedures cover these items, because you could very well need to run a parallel path here to strengthen your existing operating procedures while also performing an overview of the process training. Now that you know the actual requirements, you can put a plan together to achieve success but know that most of what the operator is going to learn is OJT, and if your operating procedures have a lot to be desired or they are just documents in a binder somewhere, you are thereby failing said operator.
These statements do not reflect my past, current, or future employers.