OSHA’s and EPA’s process safety standards require a lot of specific training in order to meet their minimum compliance requirements; however, in this article, I want to point out that although OSHA or EPA makes no specific mention of this training, the training is ABSOLUTELY NECESSARY for a functioning process safety management system.
Management of Change
There is no requirement in 1910.119(l) or 68.75 that employees be trained on the working of the MOC program. And because there is no requirement in the standard, we almost always find changes that were made by people who had no idea they should have performed a MOC for the change. When the debate amongst the facility personnel as to why an MOC was not done, the defendants can easily point to the fact that they never received any training on the MOC program. Sure they received the “annual PSM training” (also NOT a compliance requirement) but that annual training mentions MOC for about 2-3 minutes. It does NOT train personnel how to identify a “change” and more importantly it does NOT train them on how to EXECUTE a MOC.
Pre-Startup Safety Review
There is no requirement in 1910.119(i) or 68.77 that employees be trained on the working of the PSSR program. And because there is no requirement in the standard, we almost always find people who had no idea they should have performed a PSSR for the change. We also find far too many completed PSSRs that were done by personnel who were not only untrained in how the PSSR was to be performed, but they were signing off on items that they had no idea as to what they were approving. And please know that we see the same thing in the MOC system – people assigned to do S&H/Hazard reviews that have inadequate knowledge/skills to perform the critical task(s) properly.
So yes, there is nothing in either standard that requires us to have a sign-in sheet showing personnel were trained in these critical safety systems within our process safety management system; but when we find that these systems are broken and yet we have never provided the necessary training, it should be clear to us all that these programs need to have a training requirement. Heck, we see inter-squabbles between operations, engineering, and EHS regarding what sections are required to be completed, when they are to be completed, and who is responsible for completing them. And these debates are occurring in facilities that have been doing PSM since 1992 – something tells me these debates should have occurred in 1993!
But we should not be surprised when an audit finds changes with NO MOC/PSSR done and for those MOCs that were done, there are numerous errors and omissions in how the MOC/PSSR was executed. TRAINING on the site-specific MOC and PSSR programs and checklist is ESSENTIAL to ensuring the personnel responsible for participating in these efforts have the skills necessary to execute the required items.