(140b) Employee Training – Beyond Compliance

When it comes to employee’s safety at a facility covered under the Occupational Safety and Health Administration’s (OSHA’s) Process Safety Management (PSM) Standard or the United States Environmental Protection Agency’s (USEPA’s) Risk Management (RMP) Rule, training is often paramount to communicate to employees the hazards of the process and how to comprehend operating procedures so consistent operation is ensured. However, under the PSM and RMP rules, only employees who interact with the process must receive training, and the elements required to be in the training focus on the hazards of the process, the safe work practices, and overview of standard operating procedures. However, if culture and workplace involvement are some of the first pillars in the Risk Based Process Safety approach, then we must consider communicating more than just the regulatory minimum. If we also train personnel on the elements of process safety, how they work, and how they are connected, we can increase the buy-in to the process safety culture. This paper will overview how to conduct these trainings to keep personnel involved and what areas to focus on to ensure a meaningful retention and implementation. Additionally, it will also analyze the scope of employees who will be covered and structured by title. From managers who oversee individuals with responsibilities under the program to general employees. Even if a manager, such as a Plant Manager, does not have direct interaction with the program, they should be trained on what the expectation of the program is and how it potentially affects the aspects of their job. The final segment will cover an overview of the proposed changes to the USEPA’s RMP rule on training requirements for management personnel and how we can meet these changes to the rule. Through robust training in the elements throughout all levels of an organization, PSM culture can continue to evolve as employees better understand the elements, and the management systems process.