Questions cont'd - doe-hdbk-1101-20040059

DOE-HDBK-1101-2004

Rule, DOE contractors should apply the same documentation and verification

requirements for refresher training as for initial training.

66.

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.

67.

What criteria must DOE contractors use to determine whether employees

understand their training? What documentation is needed to provide evidence of

this understanding?

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.

68.

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

required?

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

adequately documented.