PSM/RMP Refresher Training Frequency is not a 1,094 day vacation from training!

Yes, it is true… 1910.119(g)(2) states

“Refresher training shall be provided at least every three years, and more often if necessary…”

Please take note that the phrase “at least every” is used preceding the 3-year frequency, as well as OSHA explicitly states “more often if necessary”.  In my 20+ years of developing, implementing and managing process safety management systems I have never encountered a single employee associated with the process that did not receive a fair amount of ANNUAL TRAINING related to their PSM/RMP duties.  But it is a major omission on OSHA’s (and EPA’s) to set the refresher training at 3 years.  Even the LOTO, PRCS, Emergency Action Plan training required for PSM do not have an annual training requirement!  So it is fair to say that OSHA’s (and EPA’s) process safety management systems do NOT require annual training.  But don’t be fooled, is not a 1,094-day vacation from training!

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