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The Unrecognized Gap: Contractor Training for PSM Facilities

October 13, 2010

While great efforts are made to insure that contractors to facilities regulated by OSHA’s PSM (Process Safety Management) standard (29CFR 1910.119) are properly trained before going onto the job, there still often remains a gap in training, especially for small contractors, that is sometimes missed.

In paragraph (h) the PSM standard states that employees of contractors to chemical plants and refineries must be trained at four levels:

  1. They must be properly trained in their skill;
  2. They must be trained to safely perform their work [Basic Orientation Plus (BOP) and other safety training];
  3. They must be trained in the rules and regulations associated with the site at which they are working including the Emergency Action Plan (site specific training); and,
  4. They must be trained in the hazards associated with process or unit that they are working in (process specific training... sometimes included in site specific training).

The training contractors currently receive covers all these levels… up to a point, and contractors sometimes make the assumption that the BOP covers everything they need. What is not understood is that the BOP is non-specific safety training; i.e., it provides the general safety awareness level training that everyone, regardless of the facility they will be working in, needs.

There are, in fact, additional needs for safety training that vary, depending on what job a contractor is doing and at what site it is being done. This is Job Specific safety training, and to date, it has been the contractors’ responsibility to intuitively determine what this job specific element entails. Below is the sequence of training contractors need under PSM:

  1.  Skills Training
  2. Job Specific Training
  3. Safety Orientation
  4. Site Specific Training
  5. Process Specific Training

Again, many small contractors are unaware that the BOP only delivers a portion of the safety-related training they need.  Large contractors, on the other hand, have more training resources available, are more aware of the gap and usually give their employees the additional training they need to fully meet OSHA’s PSM requirement.

It is important to note that the specifics of the job the contractor is on, dictate what additional training is needed.

Example A: On one job at XYZ Company, a contractor may not be required to use fall protection gear, but at a job for ABC Company, the contractor’s employees may be working at elevated heights and are required to use fall protection gear and therefore, get more in-depth training in fall protection and scaffold user training. As you can see, the job specific training requirements for the two jobs differ.

Example B: On one job at FGH Company, a contractor may not need to use a forklift, but at a job for QRS Company, the contractor’s material handling needs may require that they lease a forklift and are therefore required to get forklift training on that specific type of forklift equipment. At LMN Company they need to use a different type of forklift, and need to be trained and certified yet again on that type. Again, the job specific training requirements for the three jobs differ.

So… how do contractors determine what the job specific safety training requirements are?

They need to do a pre-job hazard evaluation and risk assessment that includes a training needs assessment. To assist in this process, facilities need to work with contractors well before work begins to identify their job specific needs. It is important that plants and contractors work together to determine what the job specific requirements are.

In addition, it is important for contractors to keep detailed records and to do the following:

  • Document training employees already have received;
  • Perform a pre-job hazard evaluation and risk assessment; and, 
  • Perform a training needs assessment to identify training employees still need.

Rick Saizan is the Education Services Manager for the Safety Council of the Louisiana Capital Area. He is a Certified Occupational Safety Specialist and holds a Masters degree from Louisiana State University in Human Resource Training and Development.

Safety

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