Training ensures that every employee involved in operating a covered process has the knowledge and skills needed to do their job safely. Under 29 CFR 1910.119(g), employers must provide initial training on process-specific hazards and operating procedures, refresher training at least every three years, and documentation that each employee has understood the training. Even the best-written operating procedures and most thorough hazard analyses are ineffective if workers are not properly trained. Ecesis PSM software delivers and tracks training through classroom and mobile-based training tools.
What OSHA Requires
Under 29 CFR 1910.119(g), employers must:
- Initial training: Each employee presently involved in operating a process, and each employee newly assigned to a process, shall be trained in an overview of the process and the operating procedures, emphasizing specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks
- Refresher training: Provided at least every three years, and more often if necessary, to each employee involved in operating a process to ensure understanding is maintained
- Documentation: The employer shall ascertain that each employee involved in operating a process has received and understood the training. A record shall be kept containing the identity of the employee, the date of training, and the means used to verify that the employee understood the training
Employees already involved in operating a process on the effective date of the standard may be certified as having received equivalent training in lieu of initial training.
Step-by-Step Implementation
Identify Training Requirements by Job Role
Map each job role involved in operating covered processes to the specific training topics required. This training matrix should identify:
- Which employees operate which covered processes
- Process-specific hazards each role is exposed to
- Operating procedures each role must understand
- Emergency shutdown and emergency operations responsibilities
- Safe work practices specific to each role
This matrix becomes the foundation for both initial and refresher training programs and helps ensure no role is overlooked.
Develop Process-Specific Training Content
PSM training must be specific to your processes, not generic safety training. For each covered process, develop training materials that cover:
- An overview of the process including what it does, what chemicals are involved, and the basic process flow
- Specific safety and health hazards: what can go wrong, what the consequences are, and what controls are in place
- Operating procedures relevant to the employee's job tasks, including normal, abnormal, and emergency operations
- Safe operating limits and the consequences of exceeding them
- Emergency shutdown procedures and the employee's specific role during emergencies
- Safety system functions (interlocks, alarms, relief devices) and what they protect against
Verify Comprehension
OSHA requires that the employer ascertain each employee has understood the training. Acceptable methods for verifying comprehension include:
- Written tests with passing score requirements
- Practical demonstrations of skills and procedures
- Oral examinations documented by the evaluator
- Observed task performance with supervisor sign-off
Simple attendance sign-in sheets do not satisfy the comprehension verification requirement. The method of verification must be documented in the training record.
Schedule and Track Refresher Training
Establish a system to automatically schedule refresher training at least every three years for each employee. Consider scheduling refresher training more frequently for:
- Processes with high turnover in operating personnel
- Processes that have undergone significant changes since last training
- Employees who have been involved in incidents or near misses
- Areas where audit findings indicate knowledge gaps
Track refresher training due dates through your compliance calendar to prevent lapses.
Maintain Training Records
Each training record must include:
- Employee name and identification
- Date of training
- Description of training content (topics covered, procedures addressed)
- Means used to verify the employee understood the training
- Results of comprehension verification (test scores, practical evaluation results)
- Trainer identification and qualifications
Retain records for the duration of employment and make them available for audit review.
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software provides a complete training management solution for PSM compliance:
- Training delivery: Create and deliver process-specific training through classroom sessions and the mobile app for anytime, anywhere access
- Comprehension testing: Built-in quizzes and assessments document that employees understood the training, not just attended
- Automatic scheduling: Three-year refresher cycles are tracked automatically with notifications to employees and supervisors
- Training matrix: Map job roles to required training and instantly identify employees who are overdue or not yet trained
- Record retention: Complete training records including dates, content, verification methods, and results are maintained and audit-ready
Frequently Asked Questions
Can existing employees be certified instead of retrained?
Yes. Employees already involved in operating a process when PSM was initially implemented can be certified as having received equivalent training based on their existing knowledge and experience, provided the certification documents the basis for determining equivalency.
Does PSM training replace HAZCOM training?
No. PSM training addresses process-specific hazards and operating procedures for covered processes. HazCom training under 29 CFR 1910.1200 covers general chemical hazard communication. Both are required independently, though PSM training content may overlap with and supplement HazCom training.
How do we train employees on process changes?
The management of change element (1910.119(l)) requires that affected employees be trained on changes before startup. This training should cover what changed, why, how it affects their operating procedures, and any new hazards introduced. Document this as supplemental training in employee records.
What qualifications must trainers have?
OSHA does not specify trainer certification requirements, but trainers should have knowledge of the process and the specific hazards being taught. Many facilities use a combination of internal subject matter experts for process-specific content and external trainers for specialized topics.
Is online training acceptable for PSM?
Online or app-based training can be effective for knowledge-based components such as chemical hazards, process overviews, and procedure reviews. However, hands-on skills such as emergency shutdown procedures and equipment-specific operations typically require practical, in-person training and evaluation.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
