Program 2 Prevention (40 CFR 68.54, 40 CFR 68.56, and 40 CFR 68.95)
Most Program 2 processes are likely to be relatively simple and may be located at small businesses. Personnel must be trained to perform the safety procedures for their part of the operation.
Initial process. Initial process training is conducted for each employee (new or presently employed) on the process, including training in the process’s hazards and the standard operating procedures as they apply to the specific job.
Maintenance. Maintenance training must be conducted for each employee involved in maintaining the ongoing mechanical integrity of the process. It includes training in hazards, avoiding/correcting unsafe conditions, and job procedures.
Change in process. Change in process training must be conducted for employees involved in operating a process and for maintenance and contract employees whose job tasks will be affected by a change in the process before start-up.
Temporary process. The actual operating procedures for running a temporary process must be written, and operators must be trained to use them, before the operation is put into place.
Despairing ever getting your employees trained? It isn’t easy to fit it in—schedule-wise or budget-wise—but now there’s the Environmental Compliance Library from Training Today. Train all your people, at their convenience, 24/7. Start Your Free Trial
Emergency response. If facility employees will respond to releases of regulated substances, the emergency response program must include training for those employees. If a facility chooses to establish and maintain on-site emergency response capabilities, it will be subject to the detailed provisions of OSHA’s HAZWOPER Standard.
Refresher training. Refresher training is required every 3 years, and more often if necessary to ensure that the employee understands and adheres to the current operating procedures of the process.
Program 3 Prevention (40 CFR 68.71, 40 CFR 68.73, 40 CFR 68.87, and 40 CFR 68.95)
Initial training must be conducted for each employee presently involved in operating a process and each employee before being involved in operating a newly assigned process. Training must include an overview of the process and the operating procedures. The training must also include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.
Maintenance training is required for each employee involved in maintaining the on-going integrity of process equipment. Each employee must be trained in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to ensure that he or she can perform the job tasks in a safe manner.
Contract employee training is required to ensure that each contract employee is trained in the work practices necessary to safely perform his or her job.
Train on demand with TrainingToday. Register today to start your FREE trial and get instant access to over 20 environmental compliance courses. Start Your Free Trial
Emergency response. If facility employees will respond to releases of regulated substances, the emergency response program must include training for those employees. If a facility chooses to establish and maintain on-site emergency response capabilities, it will be subject to the detailed provisions of OSHA’s HAZWOPER Standard.
Refresher training. Refresher training is required every 3 years, and more often if necessary to ensure that the employee understands and adheres to the current operating procedures of the process.
Recordkeeping. The facility owner or operator must record the identity of each employee trained, the date of training, and the means used to verify that the employee understood the training.