Training Requirements: RMP/PSM/CalARP Overview (Part 1 of 4)

In a 2010 survey done by IIAR, it was found that 60% of ammonia releases were caused by human error. Mechanical failure was the cause of 37% of accidental releases. Knowing that much of mechanical failure can be avoided by good inspection, tests, and maintenance, it is likely that a portion of the 37% of releases caused by mechanical failure were also affected by human error. What does this mean? It unequivocally means that human error is the cause for most accidental releases of anhydrous ammonia. While equipment can certainly fail while being maintained appropriately and there is always a possibility of other unforeseeable emergencies, training employees to handle hazardous chemicals properly will drastically lower your chance for having an accidental release of ammonia. Many facilities understand the need for training, but remain confused about what training is required to be compliant with RMP/PSM/CalARP regulations. More importantly, what training should be performed to keep their employees, property, and the surrounding area safe. This four-part blog series on training will seek to answer those questions.

When it comes to training employees, it is helpful to place employees into two broad categories: operators and general facility employees. Operators are only those employees who are monitoring or working on the system. General facility employees includes those who work on or near the system, but also includes every other employee whose job function may be unrelated to the system (e.g. accounting or human resources).

Now that we have divided all employees into two broad categories, we can examine what training is required for each type of employee. General facility employees are required to be trained on two topics: (1) chemical safety and health hazards and (2) emergency response. In addition to these trainings, operators are required to be trained on two additional topics: (1) an overview of the process and (2) operating procedures.

General facility employees need to receive their training initially, before beginning work onsite. While it is not a prescriptive requirement, regulatory agencies often expect and enforce annual refresher training. Operators require training initially with refresher training being performed at least every three (3) years. While most operators receive training on operating procedures and process overview on a more frequent basis, the minimum requirement for refresher training is at least every three years. In addition, training should be performed for any significant changes or if it is decided with employees that more frequent refresher training is necessary.

Whenever a training is provided, documentation must include the following elements:

• Date
• Training topic(s)
• Delivery method (classroom, on-the-job training, demonstration, or tailgate safety meeting)
• Method used to verify competency (demonstration, observation, discussion, oral test, or written test)
• Employee names
• Trainer name and signature

The following articles in this series will describe the specific requirement of each training as well as offer best practices for orchestrating a training program. Read Part 2, Part 3, and Part 4.