Refresher Training Frequency — OSHA Letters of Interpretation

In a letter clarifying several terms used in the PSM standard, OSHA addressed what "initial startup" means for new equipment and what it means for refresher training to be "provided" under (g)(2). Read the letter for OSHA's exact wording before relying on it in a program document.

OSHA clarified that the training rules in 1910.119(g) apply to employees operating a process. Mechanics who maintain equipment such as pressure relief devices are trained under the mechanical integrity element, (j)(3): an overview of the process and its hazards plus the procedures for their tasks. That provision has no three-year refresher requirement, but employees must be retrained if the process, hazards, or their tasks change. Employers may set the training format rather than follow equipment manufacturers' recommended courses, and maintenance staff must be trained on new equipment in a new covered plant.

Asked whether operators could lose their jobs for failing a test after refresher training, OSHA said employers need "appropriate methods, such as written tests, oral examinations, simulation exercises, etc., to ensure that employees understand the training they have received," and that "only those who have demonstrated the ability to do their jobs safely" should work on hazardous processes. OSHA declined to weigh in on employment decisions.

In a memo on a utility's plan to let employees test out of annual refresher classes, OSHA called challenge testing "an excellent tool" for confirming knowledge but "not a substitute for skills training." Where a standard requires both knowledge and work-practice refreshers, a challenge test can substitute only for the knowledge part, and an oral test must be certified by the test provider. OSHA recommended a one-year pilot with employee representatives involved.

In a letter about restarting after an extended shutdown, OSHA noted that the maximum three-year refresher training interval in 1910.119(g)(2) "is unaffected by the time a process is shutdown," and that employers should evaluate whether operators need refresher or additional training before restart.