Process Safety Management of Highly Hazardous Chemicals

OSHA Standard: 1926.64

Training Requirement: Initial training is required for each employee involved in operating a process of highly hazardous chemicals BEFORE being involved in that operation. Refresher training shall be provided at least every three years, and more often if necessary.

Training Documentation: The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Training: All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with for the protection of themselves and others. The operating procedures are often viewed as the standard operating practices (SOPs) for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures.

Training in subjects such as operating procedures and safety work practices, emergency evacuation and response, safety procedures, routine and nonroutine work authorization activities, and other areas pertinent to process safety and health will need to be covered by an employer’s training program. Because of this this, hands-on-training is strongly encouraged to be used.

Training evaluations are strongly encouraged. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved.

Audits: Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer’s systems are effectively implemented.

Evaluate: Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees.