Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

accidents and near misses;

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 empha-

sized 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 inter-

pretation and guidance concerning operating procedures should receive appropriate training.

Persons not involved in the actual operation of a covered process (e.g., janitors, plant manage-

rs) 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 train-

ing?

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 Rule, DOE

contractors should apply the same documentation and verification requirements for refresher

training as for initial training.