A recent fatality at an ammonia refrigeration process in Canada points to a potential weakness in “contractor safety” at facilities with active process safety management systems in place. PSM/RMP facilities regularly get “safety information and data” from their contractors; this information is usually the contractor’s OSHA injury/illness rates, experience modification rate, etc. But many PSM/RMP facilities have also begun (and rightfully so) to ask for copies of key safety programs and training records for these programs from their contractors. But what happens when your contractor uses a “contractor” (e.g. subcontractor) to help and those subcontractors have never been through training on the programs the PSM/RMP facility has on file. The response from the main contractor in Canada was very interesting, to say the least…