UPDATED 6/15/11 – A lot of claims are being made by many training organizations that they can solve ALL your PSM/RMP training needs. Now let me set the record straight, I think a lot of these off-site training courses are a GREAT first pass for operators and maintenance to get the baseline understanding of the process. HOWEVER… and it is a BIG, however, your training efforts are FAR FROM OVER. Now it is possible that an off-site course could meet all your needs if the course covered the EXACT SAME PROCESS, the EXACT SAME equipment used in your process, EXACT SAME process parameters (e.g., safe upper and lower limits) as your process, EXACT SAME consequences of deviations, and the EXACT SAME steps to correct or avoid the deviations as in your process, and finally, the course will provide you the verification of knowledge for ALL these topics or others. In 20-plus years of being in Chemical Process Safety, I have never seen any one (1) training school provide this in an “open enrollment” course. Sure, companies can hire these types of organizations and tailor the training specifically for their process, but this is VERY RARELY ever done.
Most of these canned courses do an excellent job on the fundamentals, and I highly recommend them to novice operators and maintenance technicians. But they ALMOST ALWAYS do NOT cover the process specifics that must be covered under the PSM/RMP training elements. Just handing an EPA inspector or an OSHA CSHO a certificate that your operators “Successfully Completed Course 101” as your PSM/RMP training documentation leaves much to be desired. And I will go out on a limb and say it opens the facility up to a substantial citation.
Most of the PSM/RMP elements are loose and allow the employer to dictate timing and content; however, you will notice that the Operating Procedures and Training elements in both PSM and RMP are quite specific as to the content of the training and the timing. The standards require specific operating procedures for the stages of our process and each of these procedures has some specific data that must be included in the SOP(s). Why would OSHA and EPA require all this specific information if they did not want the operators trained on it?
Too many facilities today (2010) do not realize that the training their personnel is REQUIRED to receive is on the Operating and Maintenance Procedures required by the Operating Procedure element. This is why the PSM/RMP training element has that 3-year window. OSHA realized early on that some processes could have hundreds (if not thousands) of operating procedures and that some of these procedures will be very detailed and complex and could take days to train someone. The intent of this 3-year window is NOT to allow facilities to conduct training every two years, 11 months, and 27 days, but rather to make training a never-ending process with the three-year window. And at the end of the three-year window, the training process starts all over. Keep two essential things in mind:
1) in some cases, training will need to be MORE OFTEN than every three years, as the 3-year window is a maximum time period, and
2) the operating procedures must be certified annually.
To comply with Operating Procedures and Training, your procedures have to include all the specific requirements, certified within the past 12 months, and your training records need to show documentation of training on ALL the procedures the employee is expected to carry out, which includes the means used to “verify knowledge” on each procedure they are trained on. And don’t forget about the maintenance personnel; they must be trained in their maintenance procedures.
Please let me know if you can find an open enrollment training course at a trade school, university, etc., that can train your personnel on these specific needs! The bottom line… it is not as easy as sending personnel to a week-long course (or two or three weeks) and thinking they are QUALIFIED! And hey, to make your head spin even more…don’t forget operators have to be trained on LOTO, CS Entry, Line Break, and Controlling Access to process area(s) to name just a few of the safe work practices specifically called out in the PSM/RMP standards. I am sure that these open enrollment courses are not covering these specific SWPs in their courses!