PSM Training question
PSM Training question
(OP)
Under PSM we are required to train our operators and verify their understanding. We have set up a training and "certification" program to do this. We also have contract employees on site who perform mostly maintenance functions however there are a few who are actual operators. These operators are directed by the same shift leads as our directly employed operators. The contract operators receive training from both us and their contract employer. The issue we are having now is, who is responsible for "certifying" these contract operators. The PSM regulation says the "employer" but it is unclear if they mean us or the contracting company. The RMP reg talks about the "owner/operator" but doesn't specifically say they must perform the certification. What do other companies do?





RE: PSM Training question
RE: PSM Training question
Since, typically, you are less than likely to get the same contract operators each time, it often makes sense to pass the responsibility on to the contractor, but you must have confidence that he will train those that he supplies to you.
RE: PSM Training question
There are two other, somewhat complementary, principles.
First, the owner/operator of a facility always holds primary responsibility and liability for safety at the facility - period. Some liability may be absorbed by contract with another employer or entity such as insurance or worker's compensation; however, the owner/operator will always hold some liability. The best that can be hoped for is reducing liability by showing all reasonable actions were taken before an injury.
Second, all persons that may validly direct work are responsible for the worker's safety. Even superiors that do not regularly direct work may be held responsible as long as they have the authority to direct work. In this case, the agency that assigned the worker. NOTE: The superior does not necessarily have to have "hire/fire" authority, just the authority to direct some aspect of the work. Oddly enough, a direct supervisor that exceeds their authority may have no liability at all; they may be fired, but unless they also did something illegal, they usually hold no personal liability.
RE: PSM Training question
Findlay OSHA Safety Training
Their main web site is All Hazards Training Center