Rule, DOE contractors should apply the same documentation and verification
requirements for refresher training as for initial training.
What criteria must DOE contractors follow and what documentation must DOE
contractors have to grandfather the initial training of existing employees?
DOE contractors should decide what criteria to use to certify that existing employees
have "the required knowledge, skills, and abilities to safely carry out the duties and
responsibilities as specified in the operating procedures." Contractors may choose to have
operating managers or supervisors for covered processes review the training and
experience level of employees already involved in operating the processes.
What criteria must DOE contractors use to determine whether employees
understand their training? What documentation is needed to provide evidence of
DOE contractors should develop their own criteria appropriate for job functions and
types of training delivered (e.g., classroom, on-the-job). Documentation should be
appropriate to the training provided. For example, test scores may be adequate to
demonstrate understanding of classroom training. In-the-field skill demonstrations or
on-the-job quizzes may also be appropriate. In every case, the means used to verify that
the employee understands the training must be documented.
The PSM Rule requires that DOE contractors make sure that operators understand
the training provided to them under this section. Is some method of testing
Some positive means must be taken by DOE contractors to ensure that employees
understand their training and are capable of adhering to current operating procedures.
Assurance could be gained through the administration of written tests, although the PSM
Rule does not require that formal written tests be used. Other means of ascertaining
comprehension, such as on-the-job demonstrations, are acceptable so long as they are