| What the regulation says:
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(g)(1) Initial
training.
(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.
(g)(1)(ii) In
lieu of initial training for those employees
already involved in operating a process on May
26, 1992, an employer may certify in writing
that the employee has the required knowledge,
skills, and abilities to safely carry out the
duties and responsibilities as specified in the
operating procedures.
(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.
(g)(3) Training
documentation. The employer shall ascertain that
each employee involved in operating a process
has received and understood the training
required by this paragraph. 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.
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| What it means:
| All
employees, including maintenance and contractor
employees, involved with an HHC need
to fully understand the safety and health hazards of the
chemical and processes they work with for the
protection of themselves, their fellow employees and the
citizens of nearby communities. Training conducted in
compliance with 1910.1200, the Hazard Communication
standard, will help employees to be more knowledgeable
about the HHC they work with as well as
familiarize them with reading and understanding MSDS.
However, additional training in subjects such as
operating procedures and safety work practices,
emergency evacuation and response, safety procedures,
routine and non-routine work authorization activities,
and other areas pertinent to process safety and health
will need to be covered by an employer's training
program.
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| In
establishing their training programs, employers must
clearly define the employees to be trained and what
subjects are to be covered in their training. Employers
in setting up their training program will need to
clearly establish the goals and objectives they wish to
achieve with the training that they provide to their
employees. The learning goals or objectives should be
written in clear measurable terms before the training
begins. These goals and objectives need to be tailored
to each of the specific training modules or segments.
Employers should describe the important actions and
conditions under which the employee will demonstrate
competence or knowledge as well as what is acceptable
performance.
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| Hands-on-training
where employees are able to use their senses beyond
listening, will enhance learning. For example, operating
personnel, who will work in a control room or at control
panels, would benefit by being trained at a simulated
control panel or panels. Upset conditions of various
types could be displayed on the simulator, and then the
employee could go through the proper operating
procedures to bring the simulator panel back to the
normal operating parameters. A training environment
could be created to help the trainee feel the full
reality of the situation but, of course, under
controlled conditions. This realistic type of training
can be very effective in teaching employees correct
procedures while allowing them to also see the
consequences of what might happens if they do not follow
established operating procedures. Garden City College in
Kansas offer just suck training. Other training
techniques using videos or on-the-job training can also
be very effective for teaching other job tasks, duties,
or other important information. An effective training
program will allow the employee to fully participate in
the training process and to practice their skill or
knowledge.
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| 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. The means or methods for evaluating
the training should be developed along with the training
program goals and objectives. Training program
evaluation will help employers to determine the amount
of training their employees understood, and whether the
desired results were obtained. 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.
Those who conducted the training and those who received
the training should also be consulted as to how best to
improve the training process. If there is a language
barrier, the language known to the trainees should be
used to reinforce the training messages and information.
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| Careful
consideration must be given to assure that employees
including maintenance and contract employees receive
current and updated training. For example, if changes
are made to a process, impacted employees must be
trained in the changes and understand the effects of the
changes on their job tasks (e.g., any new operating
procedures pertinent to their tasks). Additionally, as
already discussed the evaluation of the employee's
absorption of training will certainly influence the need
for training. |
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