Under 29 CFR 1910.119(g)(1), each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, must be trained in an overview of the process and in the operating procedures in paragraph (f), with emphasis on specific safety and health hazards, emergency operations including shutdown, and safe work practices. Employees already operating a process on May 26, 1992 could instead be certified in writing as having the required knowledge, skills, and abilities. OSHA's letters add two practical points: this element is about operators, and training has to be verified, not just delivered.
What OSHA Has Said
Feb 4, 2013
Operator training vs. maintenance training
OSHA clarified that the training rules in 1910.119(g) apply to employees operating a process. Mechanics who maintain equipment such as pressure relief devices are trained under the mechanical integrity element, (j)(3): an overview of the process and its hazards plus the procedures for their tasks. That provision has no three-year refresher requirement, but employees must be retrained if the process, hazards, or their tasks change. Employers may set the training format rather than follow equipment manufacturers' recommended courses, and maintenance staff must be trained on new equipment in a new covered plant.
Read OSHA Letter ↗
May 28, 1993
Testing whether operators actually understand
Asked whether operators could lose their jobs for failing a test after refresher training, OSHA said employers need "appropriate methods, such as written tests, oral examinations, simulation exercises, etc., to ensure that employees understand the training they have received," and that "only those who have demonstrated the ability to do their jobs safely" should work on hazardous processes. OSHA declined to weigh in on employment decisions.
Read OSHA Letter ↗
Jun 23, 2023
OSHA clarifies 'initial startup' and 'provided'
In a letter clarifying several terms used in the PSM standard, OSHA addressed what "initial startup" means for new equipment and what it means for refresher training to be "provided" under (g)(2). Read the letter for OSHA's exact wording before relying on it in a program document.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
Train every operator on the process overview and the actual operating procedures before they run a newly assigned process, and prove they understood it with a test, demonstration, or simulation. Train maintenance staff under the mechanical integrity element instead, focused on the process hazards and their task procedures. Plan both before initial startup, when chemicals go in for the first time.
