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!
We have to keep in mind that PSM/RMP standards are PERFORMANCE ORIENTED standards , thus this is a “3-year WINDOW” in which personnel is REQUIRED to have received refresher training on ALL procedures and practices they use in executing their PSM/RMP duties. This includes the SOPs, Maintenance Procedures, Safe Work Practices, and Emergency Procedures.
Even in the smallest, most basic, of PSM/RMP, covered processes this training obligation can be quite large. So large, that when a good auditor or compliance officer notices that ALL training for PSM was done in one session that was a couple of hours long – RED FLAGS get raised.
OSHA and EPA provided this 3-year window because this training can be a monumental obligation to the facility. I like to say that PSM/RMP training is a MONTHLY, if not a weekly, task. Even facilities with one (1) covered process can break down their PSM/RMP training obligations and find that the quantity of training necessary over this three year period is such that an operator can easily need to receive training each week. After all, we are only talking about 156 weeks in this period and I can easily find 150 training (and tasks related to training) needs for an operator involved in a PSM/RMP covered process. Add on an additional covered process or operators doing some “maintenance tasks” and my job of reaching 152 topics becomes even easier.
So the question comes up… Why does OSHA require annual SOP certification, but refresher training every three years? OSHA/EPA intended these functions to be entirely separate from one another. The annual SOP review and certification is meant to serve as a SECONDARY exercise on top of MOCs to ensure that SOPs still reflect reality within the process. Keep in mind that a lot of facilities actually use their SOPs and some even REQUIRE them to be “in hand” while executing the task(s). There is absolutely no way anyone can be expected to memorize all the procedures they use in a day of running a chemical process – it is IMPOSSIBLE; so SOPs and SWPs MUST become a usable document that is used often. OSHA (and EPA) realized this and thus they want the procedures certified annually.
But of course, any issues with the SOPs found during the annual review MUST BE addressed and MOCs are the vehicle(s) to make the necessary revisions to the SOPs. This, of course, brings TRAINING into the annual review and certification process. Sure there are facilities that annually certify their procedures like clockwork. Even still today, it is not uncommon for us to find some major errors in the SOP document, as well as in the implementation of the SOP/SWP. During our audits we will take several key SOPs and walk them down with a senior operator (someone who has done the tasks many times); usually within the first 15 minutes, we find errors, some of which are SAFETY CRITICAL. It is not that uncommon to find equipment that is no longer in place still mentioned in the SOP or the SOP mentions equipment that was never in place. Yet the operator(s) state they follow this SOP by the letter each time the task is done. These SOPs go years with annual certifications having never caught these major errors. Makes one question the authenticity of their annual review and certification process.
I have yet to find that safety management system that is so perfectly executed that an annual review of all SOPs results in no issues. Even when a facility is well disciplined in their MOC process, things get missed! Often times is the case that certain information resides in multiple documents, yet the MOC manager is NOT aware that this information resides in multiple documents. So he/she makes the updates to those documents they know of, missing a couple they are not aware of. An auditor arrives (or OSHA/EPA) and just happens to review one of those omitted documents and finds that the document is not accurate, even though it had been annually certified. Now the entire review and certification process comes into question and you can bet any experienced auditor (and OSHA/EPA) will dig deeper to determine is this just a “one-off” or is the “system broken”.
So what if an error is found in the annual SOP review… Are you stating that an MOC is needed to make the correction? Yes, in most cases. There are some corrections that can be made to an SOP that does not impact operator/maintenance safety or the process safety. Things like simple grammatical corrections, corrections/changes to the revision number, changing the logo on the SOP, etc. These changes would not require an update to the PSI or any retraining so I would argue no MOC is necessary for the name of safety. However, when we begin to tinker with “safety systems”, set points, consequences of deviation, steps to avoid/correct deviations, PPE requirements, valve #’s, etc. these are SUBSTANTIAL changes that MUST be communicated to ALL that will be impacted. Notice I used the term “communicated” rather than “training”. In many cases, merely informing the personnel of the change is adequate, which is a far cry from actual “training”. But an MOC is still necessary to ensure that we update and inform everything/everyone impacted and the MOC is the tool we use to ensure this is done.
Lastly, please do not forget about the Safe Work Practices that are part of our process safety management system. OSHA and EPA specifically call out LOTO, PRCS, Line Break in section (f), as well as Hot Work and Emergency Response procedures have their very own elements. If we were to look at all the “written programs” that should fall under our process safety management system we can directly tie the following back to our operators, maintenance, and contractor personnel:
- Lockout/Tagout (LOTO)
- Permit-Required Confined Spaces (PRCS)
- Process/Line Opening
- Emergency Action Plan and Emergency Response Plans for those who have response teams
- Hot Work
- PPE Programs, including respiratory protection program if operators/maintenance/contractors utilize them in their duties (even on a voluntary basis)
- HAZCOM, especially of SDS(s) are used as part of the PSI
None of these SWP standards require annual training (nor do most written programs), but most of them specifically call out refresher training anytime there is a change to the program.
I hope you can begin to see how it is a stretch to believe that PSM/RMP training is merely done every three (3) years. A well-managed management system will entail FREQUENT training over these three (3) years, even when there are no “official changes requiring an MOC”.