Safety talk on High Risk training

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Oregon Occupational Safety and Health Division Oregon Administrative Rules AO 3-2019 Division 2 Operating procedures and instructions are important for training operating personnel. The operating procedures are often viewed as the standard operating practices (SOPs) for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures. If workers are not fluent in English then procedures and instructions need to be prepared in a second language understood by the workers. In addition, operating procedures need to be changed when there is a change in the process as a result of the management of change procedures. The consequences of operating procedure changes need to be fully evaluated and the information conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department (like changing a valve from steel to brass or other subtle changes) need to be evaluated to determine if operating procedures and practices also need to be changed. All management of change actions must be coordinated and integrated with current operating procedures and operating personnel must be oriented to the changes in procedures before the change is made. When the process is shutdown in order to make a change, then the operating procedures must be updated before startup of the process. Training in how to handle upset conditions must be accomplished as well as what operating personnel are to do in emergencies such as when a pump seal fails or a pipeline ruptures. Communication between operating personnel and workers performing work within the process area, such as nonroutine tasks, also must be maintained. The hazards of the tasks are to be conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks. When the work is completed, operating personnel should be informed to provide closure on the job. - 6. Employee Training. All employees,…

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Oregon Occupational Safety and Health Division Division 2 - (c) Training. Employers shall provide training in the various precautions and safe practices described in this section and shall insure that employees do not engage in the activities to which this section applies until such employees have received proper training in the various precautions and safe practices required by this section. However, where the employer can demonstrate that an employee is already trained in the precautions and safe practices required by this section prior to his employment, training need not be provided to that employee in accordance with this section. Where training is required, it shall consist of on-the-job training or classroom-type training or a combination of both. The employer shall certify that employees have been trained by preparing a certification record which includes the identity of the person trained, the signature of the employer or the person who conducted the training, and the date the training was completed. The certification record shall be prepared at the completion of training and shall be maintained on file for the duration of the employee's employment. The certification record shall be made available upon request to the Assistant Secretary for Occupational Safety and Health. Such training shall, where appropriate, include the following subjects: - (1) Recognition and avoidance of dangers relating to encounters with harmful substances and animal, insect, or plant life; - (2) Procedures to be followed in emergency situations; and, - (3) First aid training, including instruction in artificial respiration. Note: See OAR 437, Division 2/K, Rule [redacted phone], for Medical Services and First Aid requirements. - (d) Employee protection in public work areas. Note: Federal rule 1910.268(d)(1), was NOT adopted by OR-OSHA. Instead, OAR 437-0020316(2)(a) applies: - [redacted phone] (2) Employee protection in public work areas - (a) Before work is begun in the vici…

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## 29 CFR 1910 (OSHA) in starting up or shutting down the process. In these cases, different parameters will be required from those of normal operation. These operating instructions need to clearly indicate the distinctions between startup and normal operations such as the appropriate allowances for heating up a unit to reach the normal operating parameters. Also the operating instructions need to describe the proper method for increasing the temperature of the unit until the normal operating temperature parameters are achieved. Computerized process control systems add complexity to operating instructions. These operating instructions need to describe the logic of the software as well as the relationship between the equipment and the control system; otherwise, it may not be apparent to the operator. Operating procedures and instructions are important for training operating personnel. The operating procedures are often viewed as the standard operating practices (SOPs) for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures. If workers are not fluent in English then procedures and instructions need to be prepared in a second language understood by the workers. In addition, operating procedures need to be changed when there is a change in the process as a result of the management of change procedures. The consequences of operating procedure changes need to be fully evaluated and the information conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department (like changing a valve from steel to brass or other subtle changes) need to be evaluated to determine if operating procedures and practices also need to be changed. All management of change actions must be coordinated and integrated with current operating procedures and operating personnel must be oriented to the changes in procedures before the change is made. When the process is shut down in or…

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## 29 CFR 1910 (OSHA) 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 happen if they do not follow established operating procedures. 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. 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 sh…

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## OCCUPATIONAL HEALTH AND SAFETY, 2020 - (4) If respiratory protective devices are used only for emergency purposes, an employer or contractor shall ensure that a worker who may be required to use a respiratory protective device is given semi-annual refresher training in its safe use. - (5) An employer shall ensure that the following records are kept as long as the worker who was provided with a respiratory protective device is employed by the employer and that the following records are made readily available for inspection and examination by the committee or the representative, as the case may be: - (a) records respecting fit-testing for each worker that is completed pursuant to subclause (1) (a) (iv); - (b) records respecting the results of assessments for each worker that are completed pursuant to clause (2) (d); - (c) records respecting training completed by each worker pursuant to subsections (2) and (3). - (6) An employer shall ensure that any records mentioned in clause (5) (b) respecting a worker that are made available for inspection and examination pursuant to subsection (5) do not disclose any personal health information as defined in The Health Information Protection Act respecting the worker, unless the worker agrees to that disclosure. - (7) An employer shall ensure that records respecting the maintenance of atmosphere-supplying respirators are kept and made readily available for inspection and examination by the committee or the representative as long as the worker who was provided with an atmosphere-supplying respirator is employed by the employer. - (8) A worker may, at any time, inspect and examine any records kept pursuant to subsection (5) or (7) that relate to the worker. 31 Dec 2020 c S-15.1 Reg 10 s7-3. ## Inspection of respiratory protective devices - 7-4 An employer or contractor shall ensure that: - (a) any respiratory protective device for emergency use is thoroughly inspected by a competent p…