operating limits, the consequences of deviations, and the steps required to avoid
equipment and process parameters, such as pressure, flow, and temperature.
Review of initial training elements is needed because process practices change over time and
may not reflect desired procedures or behaviors. Thus, management must emphasize the
importance of procedures and behaviors during training reviews . The following elements
should be emphasized in refresher training.
Current operating procedures of the process.
Impacts of recent or planned process and equipment changes.
Changes in equipment and process parameters such as pressure, flow, and temperature.
Process accidents, incidents, or near misses.
Written tests provide assurance that training is effective, although the PSM Rule does not require
that formal written tests be used. DOE contractors may choose to have operating managers or
supervisors from covered processes review the training and experience level of employees
already involved in operating the processes [Q66, Q67, Q68].
Which employees must receive training (e.g., operators, engineers, shift foremen,
janitors, plant managers)?
DOE contractors should develop an appropriate level of initial and refresher training for
every worker involved in operating a covered process, including operators and other
employees expected to carry out duties specified in the operating procedures. In addition,
because the preamble to the PSM Rule specifically states that "this paragraph [operating
procedures] is not intended to be limited to equipment operators," supervisors and
managers who provide interpretation and guidance concerning operating procedures
should receive appropriate training. Persons not involved in the actual operation of a
covered process (e.g., janitors, plant managers) are not required to have process-specific
training as defined by the PSM Rule.
What topics must be covered in refresher training? Is there a minimum amount of
time DOE contractors must spend on refresher training? How often should
refresher training be conducted? Must contractors document that employees
understand refresher training?
Contractors should develop topics based on the operating procedures appropriate for each
job. Because of the performance-based nature of the PSM Rule, no minimum number of
hours or frequency for refresher training is specified. The frequency of refresher training
should be determined by consulting with employees involved in operating a process, but
it must be provided at least every 3 years. Although not specifically stated in the PSM