14 PSM Elements
5. Training
Employers must provide initial and refresher training to all employees involved in PSM-covered processes, including emergency operations such as loss-of-containment scenarios. Training depth varies by role—operators need detailed instruction, while visitors or non-operators require only awareness training. Contractors and temporary workers must also be trained on potential fire, explosion, and toxic release hazards related to their work.
Storage facility training may include proper container handling, grounding during transfers, understanding chemical hazards, and following administrative rules such as hazard-area designations and restricted-access zones. Employees must recognize and respond appropriately to even small chemical releases. Other OSHA standards (e.g., HazCom, HAZWOPER, PPE, Powered Industrial Trucks) may also require training. Refresher training must be provided at least every three years, or more often if needed.
Examples: Refinery workers receive training on H₂S hazards and emergency shutdowns in sulfur recovery units; certification verifies understanding for new assignees to gas dehydration systems.
6. Contractors
The PSM standard requires employers to carefully manage contractors who perform work on or near covered processes. This includes evaluating a contractor’s safety performance before hiring, ensuring they are qualified to work in hazardous environments, and confirming that they have appropriate training, procedures, and experience for the tasks they will perform.
Employers must inform contractors of the specific process hazards they may encounter, the applicable safety and health procedures, and any known fire, explosion, or toxic release risks. Contractors must also train their own employees so they understand these hazards, follow safe work practices, and comply with the host employer’s requirements. Once work begins, the employer must periodically monitor contractor performance to ensure compliance, correct unsafe behaviors, and verify that contractor employees are following established procedures.
In the oil and gas industry, contractor management is especially critical because large portions of maintenance, construction, and specialized technical work are performed by third parties. This includes turnaround activities in refineries, equipment overhauls in gas plants, well-site services, pipeline integrity work, and catalyst handling operations. These tasks often involve elevated risks—such as confined space entry, hot work, lifting operations, or opening process equipment—making it essential that contractors understand and adhere to process safety requirements.
Examples: During a refinery shutdown, contractors are trained on HF alkylation hazards and emergency actions; employers maintain injury logs and evaluate safe access practices.
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7-4. Who must receive initial and refresher PSM training?
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