Questions cont'd - doe-hdbk-1101-20040058

DOE-HDBK-1101-2004

operating limits, the consequences of deviations, and the steps required to avoid

deviations;

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 [65]. 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].

Questions

64.

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.

65.

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