Training Requirements: Operating Procedures (Part 4 of 4)

The first article in this four-part series on training provided an overview of RMP/PSM/CalARP training requirements and the second article covered training requirements for general facility employees. While the third article explained process overview training, this fourth and final article will explain training operators on operating procedures (SOPs).

After operators understand how their system works, they need to learn how to operate it. The main idea is that employees need to be trained for every operation they are required to perform. Operators and trainers we work with are often relieved to hear this. If operators drain oil from their ammonia refrigeration system, they need to be trained to do so. If your facility relies on qualified contractors to drain oil, it is unnecessary for employees to be trained for this task.

Almost every facility has their own employees monitor the system. This is a task that operators need to be trained to perform. If your employees are monitoring the system, are they able to determine if the equipment is outside the operating parameters? These are good topics for discussion while training operators to monitor your system. Many facilities also have their operators start up and shut down their systems; this would be another task they would need training for. If ammonia operators will activate the emergency refrigeration switch (E-stop) or will close the King Valve in the event of an emergency, they need detailed training on when these measures should be taken and when conditions prohibit them from taking such actions.

Safety training topics that correspond with operating procedures are often missed. Do your operators clean your condenser(s)? Then they need to be trained on your confined space entry program. Do your operators drain oil? Then they need to be trained on your respiratory protection program. Do your operators replace pipes or PRVs? Then they need to be trained on your lockout/tagout (LO/TO) program. Federal OSHA’s PSM regulation Title 29 CFR §1910.119(f)(iv)(4) states: “The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.” Based on the amount of the violations we have seen, these programs are a primary concern for CalOSHA.

While all training should have a means to verify competency, it is especially important for operators to know and understand their SOPs. No reasonable person expects operators to have their SOPs memorized, but they should know how to reference and navigate them. To verify operators have this level of competency, we most often recommend they take a written quiz based on their SOPs with emphasis on the tasks they are required to perform. This is a great way for operators to become familiar with their SOPs if they aren’t already. (Tip: Developing quizzes for your operators should not be seen as a daunting tasks. Google forms is a free tool that provides a simple interface with automatic scoring and even allows for easy uploading of pictures.)  As with Process Overview training, refresher training should be provided at least every three years.

This four-part series has sought to explain the minimum requirements and best practices to adhere to the RMP/PSM/CalARP training regulations. General employees should receive a combined training initially and annually on chemical safety and health hazards and emergency response. Operators are required to be trained on operating procedures and process overview initially and at least every three years. While some processes are simple and straightforward, there are others that require years of training for full mastery. Finding the right training solutions for your facility, whether in-house or outsourced, will keep you compliant, efficient, and safe.