19.1 Develop a formal program for initial training of new employees and employees placed in new positions or jobs. • Acquire or develop training materials (e.g., notebooks, videos).
Select and develop qualified instructors.
• Include appropriate subject matter such as hazard recognition techniques, safe operating limits, MSDSs, start-up/shutdown/maintenance procedures and compliance requirements for applicable laws and regulations.
• Develop consistent training plans that combine classroom training with field simulations and on-the-job training. Include key elements and required proficiency levels.
• Use operating personnel to help develop the training program.
19.2 Provide means for evaluating employee proficiency with newly taught material, including tests and standard performance criteria.
19.3 Periodically assess the performance of training instructors and programs through competency checks, opinion surveys, etc.
19.4 Administer supplemental training to employees whenever changes are made to process designs or operating procedures.
PITFALLS AND CONSIDERATIONS
Sometimes, training programs don't use the right blend of classroom and field training. One-dimensional training programs can become stagnant, and instructors can become perfunctory and stale. Total reliance on on-the-job training by experienced operators may result in transfer of shortcuts, unsafe work practices and bad habits to new employees. Periodically changing training instructors and using newly "graduated" employees can help sustain training program interest and vigor.
Management Practice 20: Employee Proficiency
Demonstrations and documentation of skill proficiency prior to assignment to independent work, and periodically thereafter
Once personnel have been selected based on their skills and are trained to use good work practices and procedures, periodic demonstration of competence is necessary to ensure long-term safe operation. Methods should be developed to ascertain competency and objective performance criteria should be developed to evaluate the effectiveness of on-going training. Also, as process designs and procedures change and as new people are transferred in or advance through the job ranks, undesired changes in work practices may occur. Programs for continual renewal of workforce skills should be coordinated with the facility's management of change process (MP10).
PROCESS SAFETY ACTIVITIES
20.1 Use performance evaluations at the end of training programs. Develop written or computer-aided tests.
Create on-the-job proficiency tests.
20.2 Identify specific skill or knowledge deficiencies and provide remedial training. • Create special recurrent training programs.
Establish a work-sharing or buddy system for matching inexperienced workers with veterans. Identify temporary work positions for employees who fail to meet competency checks.
20.3 Maintain a written inventory of demonstrated skills and knowledge for each employee. Document the training, testing and qualification criteria.
20.4 Provide opportunities for employees to practice their skills in handling abnormal situations. • Arrange periodic emergency drills.
• Use process simulators to challenge operators to deal with recovery from upset conditions.
20.5 Periodically audit skill inventories and job assignments to ensure that no one is working in a position for which they are not qualified.
• Establish a system for ensuring adequate screening of vacation relief for normal shifts. • Develop a pool of replacement employees that can substitute in several key positions.
• Review personnel assignments for maintenance turnarounds, vacation schedule relief, and contractors. 20.6 Periodically survey the performance of the incumbent workforce to determine compliance with practices and
procedures.
P1TFALLS AND CONSIDERATIONS
Management Practice 21: Fitness of Duty
Programs designed to assure that personnel in safety critical jobs are fit for duty and are not compromised by external influences, including alcohol and drug abuse
Knowledgeable, well-trained, veteran employees alone will not ensure safe operations that are free from human errors. Employees must also be physically able, mentally alert and capable of using good judgment to properly follow prescribed practices. Encourage employee involvement in the development and implementation of policies and programs to eliminate substance abuse.
PROCESS SAFETY ACTIVITIES
21.1 Have a plan for dealing with cases of suspected incapacity to perform jobs safely.
• Identify jobs considered as "safety critical" where incapacity might result in improper performance and lead to a significant process failure or incident.
Establish employment screening practices.
• Define appropriate facility security measures for search and seizure of contraband in accordance with legal requirements.
• Develop a policy that will be followed by management when incapacity is suspected. • Establish appropriate rehabilitation/assistance programs for employees.
• Communicate the plan to employees.
21.2 Train supervisors to recognize the symptoms of physical or mental incapacitation and how to deal with it when suspected. The symptoms of drug and alcohol abuse should be given particular attention.
• Identify pertinent federal and state regulations.
• Provide guidance to supervisors concerning how to protect the facility while respecting personal rights. 213 Integrate "fitness for duty programs with existing human resource policies. Provide a mechanism for employee
feedback.
21.4 Train employees to know their responsibilities and personal legal exposures relative to intervention with any employees suspected of performance-affecting incapacities that may affect safe job performance.
PITFALLS AND CONSIDERATIONS
This area raises many legal issues. All "fitness for duty" programs should be developed in concert with legal counsel. Companies across the industry have wide ranging policies with regard to employee assistance programs, second chances, etc.
Management Practice 22 Contractors
Provisions that contractors either have programs for their own employees insistent with applicable sections of this Code or be included in the member compass program, or some combination of the two
Contractors can influence and be affected by fires, explosions and accidental chemical releases in the same way that member company employees can be. Sometimes, because their work activities are normally associated with plant areas undergoing a "change" of some kind (e.g., inspection, maintenance, construction), contractors may be exposed to particularly hazardous situations. The obligation of training contract employees remains with the contractor firm's management. However, companies should cooperate to the fullest extent possible to assure that the training is carried out by the contractor and should monitor jobsites to enforce applicable company safety policies and procedures.
PROCESS SAFETY ACTIVITIES
22.1 Develop a program for dealing with contractor safety issues.
• Identify types of contractor jobs that have a direct bearing on process safety.
• Establish in the purchasing organization a list of qualified bidders whose safety programs have been determined to be consistent with applicable sections of the Process Safety Code.
• Develop criteria for selecting contractors based on safety performance.
• Establish responsibility for ensuring contractor safety performance while on-site. • Communicate the program to company employees.
22.2 Provide contractors with company safety program information relevant to the contractor's work and ensure that the contractor's program addresses these requirements.
• Establish contractual provisions that require contractors to acknowledge and adhere to company on-site safety requirements.
• Develop a contractor orientation program package to be supplied to contractors as a part of the purchasing process. • Establish a procedure to review the contractor safety program, including inspecting written material, contractor
facilities and lost-time injury records.
22.3 Provide appropriate safety orientation for contract workers.
• Classify possible contractor job assignments according to the potential for workers creating and/or being exposed to process hazards in the workplace.
• Develop a brief videotape presentation on the general hazards associated with your facility.
• Issue emergency response information cards as a reminder of the actions that on-site contract workers should take. • Issue dated passes for contractors to document their participation in a safety orientation program.
22.4 Develop a system for monitoring contractor work practices in the field, verifying compliance with company safety policies, and providing feedback to contractor management.
• Perform periodic safety audits of contractor work sites.
• Have contract workers attend appropriate company safety meetings-
• Review documentation associated with hot work permits and related programs to verify contractor use. • Provide periodic reports to contractors concerning their workers' safety performance.
• Have company maintenance supervisors meet regularly with contractor supervision to discuss safe work practice topics pertinent to their planned activities.
• Develop a contractor recognition program to acknowledge good and improved safety performance of contractors. • Interact with local contractor associations or councils to discuss common process safety-related issues.
PITFALLS AND CONSIDERATIONS
The bottom line on process safety relative to contractors is that a company should take reasonable measures to assure that contract workers are subject to safety policies, procedures and practices that are equivalent to safety requirements of member companies. Moreover, companies should consistently enforce their own safety rules regarding on-site contractor work activities. The program you employ to promote contractor safety should respect that contractors must retain and exercise the responsibility for training their own employees. However, it is incumbent on facilities that hire contract workers to take reasonable measures to provide adequate information, and to enforce existing safe company work practices in a consistent fashion.