As this year comes to a close, I was reminded by a FaceBook post of a common misconception regarding 1910.119(f)(3), which is actually two (2) separate requirements/actions stated in a single paragraph of the standard. The standard states:
1910.119(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.
As we can see there are two (2) distinct actions stated above and it is the fact that these actions are DISTINCTLY DIFFERENT that I want to discuss.
When we break down 1910.119(f)(3) we see that our FIRST requirement is to review our operating procedures “as often as necessary to assure that they reflect current operating practice”. I like to call this the annual review, but we can’t lose sight that some operating procedures may need to be reviewed more frequently; the annual requirement is the absolute minimum frequency.
The next sentence is the requirement that these operating procedures be CERTIFIED that they are indeed “current and accurate”.
So these are two (2) separate exercises, which are often done by different individuals/groups. And we have not even made it to the “training” element yet, as BEFORE we can train on the operating procedures we MUST FIRST ensure they are “current and accurate”.
So once we have certified our SOPs, we can then conduct “training” on said SOPs if it is necessary. Remember, both OSHA and EPA process safety standards, require refresher training on the operating procedures at least every three (3) years, but a lot of facilities have learned that the 3-year window is actually a small window to maintain just the complaint measures which are often times a far cry from a safe process. This means that a lot of facilities are managing their operating procedure reviews like a maintenance work order. They have each operating procedure in their CMMS and it kicks out a work order to ensure that procedure is reviewed. Those facilities that are truly managing process safety will have a written procedure as to how this annual review is to be carried out (SAFTENG members can read my 2012 posting “Annual SOP Certifications for PSM/RMP”).
But the bottom line here is, doing your “annual review” should never, in NO WAY, be considered operator training. We could claim it to be some “process safety training” but NEVER should we try and pass off these reviews as “training” meaning to comply with 1910.119(g). We have seen a lot of operators trained on operating procedures that were later found to be flawed and when we ask for training records we are provided documentation that the operator(s) participated in the desk-top review and/or the field walk down during the “annual review”. Facilities are getting better at their annual reviews and they will be the first to tell you that each year they still find things wrong with their procedures.
And that leads us to the MOC discussion for another rainy day…