Refresher Training and SOPs
A recent email we received is all too common:
I’m being told we have to train operators on all SOP’s annually along with our annual recertification of all of our SOP’s. I was only aware we were required to do an initial training and a refresher every three years. Our plants PSM program says we will do an initial and three year refresher trainings. We review our SOP’s every year but do not retrain all operators each year. I just want to make sure what we are doing is correct and I’m not wrong here. Retraining all operators on all SOP’s every year is a new one to me.
Our first commandment of PSM is: Whenever ANYONE tells you about some “requirement” that you haven’t heard about before, demand that they show you their source.
If you chase every “requirement” that somebody heard from somebody else, you’ll go insane. Often when you demand a source you are going to find out that their “requirement” is someone else’s opinion, suggestion or policy rather than an actual requirement.
So, what is actually required when it comes to SOPs and training?
Our second commandment of PSM is: Go to the law!
In this case, the law for the PSM and RMP Training element are identical so we’ll quote OSHA’s PSM language:
1910.119(g)(1)(i) – Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.
This is the part where you have to provide initial training on the SOPs applicable to the work you are going to have them perform. It seems like you have this part already taken care of, so we’ll move on to the troublesome portion…
1910.119(g)(2) – Refresher training. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.
The law above sets a limit: Refresher training has to be conducted at least every three years but it also sets a performance basis. The performance basis is the part that can confuse us because the answer may well be different for each operator. The performance basis is “to assure that the employee understands and adheres to the current operating procedures of the process.”
If we’re talking about a procedure that your operators rarely use, they might forget it but hopefully your program is set up so that operators review the procedure before they implement it and come to you with any questions they have. What we’re dealing with here though is the understanding of the procedure. Your employees shouldn’t come to un-understand something they once understood unless they have Alzheimer’s or brain trauma, so we’ll focus on the second part: “adheres.” Pulling out the dictionary, the definition of adheres we are using is “to bind oneself to observance to.” Or put another way: Are they following the procedures? If they aren’t you need to train them more often to ensure that they do.
Your question also brushes up against the SOP element, so let’s look at the law there as well:
1910.119(f)(3) – The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.
The last part of the law is the part that requires you to certify your operating procedures are current and accurate – something you have to do annually. Unfortunately, the review is not tied to the annual certification because they have set up another performance basis for it. In this case the performance basis is: as often as necessary to assure that they reflect current operating practice.
You see how this requirement and the training requirement reinforce each other here? The training element requires that you make sure your operators are adhering to the SOPs and the SOP element is making sure that your SOP reflects what your operators are actually doing!
How you tackle this is up to you, but here’s part of how we handle these requirement in our GCAP template program:
- Operators are asked to review the procedure every time they perform it.
- Supervisors are asked to observe operators performing work on a regular basis to ensure they adhere to the written SOP. If they are found not adhering to the SOP, they are retrained and, if necessary, admonished.
- Operators are asked annually to provide feedback on refresher training.
- An annual training is conducted which goes over Line & Equipment Opening, the importance of SOP adherence, last year’s incidents, etc.