Safety Competency Assessment and Assurance Verification Procedure

This document outlines the procedures for assessing and verifying the safety competency of personnel involved in hazardous waste operations and emergency response, process safety management, and other safety-critical roles. It details the requirements for training, refresher training, competency demonstration, and the maintenance of records to ensure that employees can safely and effectively perform their duties.

General Requirements

Training and Competency

Employees who are involved in hazardous waste operations and emergency response must receive adequate training to perform their duties safely. Trainers must have completed a training course for teaching the subjects they are expected to teach or have the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are to teach. [1]

Refresher Training

Employees trained in accordance with specific hazardous waste operations and emergency response requirements must receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly. A statement shall be made of the training or competency, and if a statement of competency is made, the employer shall keep a record of the methodology used to demonstrate competency. [1] [1]

Competency Assessment Methods

Competency can be demonstrated through various methods, including:

• Written Examinations: To assess the theoretical knowledge of safety procedures, hazard recognition, and emergency response protocols.
• Practical Demonstrations: To evaluate the ability to perform tasks safely and effectively, such as using personal protective equipment (PPE), operating equipment, and responding to simulated emergencies.
• Skills Assessments: To measure specific skills required for the job, such as confined space entry, lockout/tagout procedures, and hazardous material handling.
• Performance Evaluations: Regular evaluations by supervisors to observe and document employee performance in real-world situations.

Specific Roles and Competencies

First Responder Awareness Level

First responders at the awareness level must understand their role in the emergency response plan, including site security and control, and be familiar with the U.S. Department of Transportation's Emergency Response Guidebook. They should also be able to recognize the need for additional resources and make appropriate notifications to the communication center. [1] [1]

First Responder Operations Level

First responders at the operations level must have at least eight hours of training or sufficient experience to demonstrate competency in hazard and risk assessment techniques, proper use of personal protective equipment, basic hazardous materials terms, basic control, containment, and/or confinement operations, basic decontamination procedures, and relevant standard operating procedures and termination procedures. They are trained to respond defensively to protect nearby persons, property, or the environment without trying to stop the release. [1] [1] [1] [1] [1] [1] [1] [1] [1]

Hazardous Materials Technician

Hazardous materials technicians require at least 24 hours of training equal to the first responder operations level. They must know how to implement the employer's emergency response plan; classify, identify, and verify known and unknown materials; function within an assigned role in the Incident Command System; select and use proper specialized chemical personal protective equipment; understand hazard and risk assessment techniques; perform advanced control, containment, and/or confinement operations; understand and implement decontamination procedures; understand termination procedures; and understand basic chemical and toxicological terminology and behavior. These technicians take a more aggressive role in stopping the release of hazardous substances. [1] [1] [1] [1] [1] [1] [1] [1] [1] [1] [1] [1]

Hazardous Materials Specialist

Hazardous materials specialists also require at least 24 hours of training equal to the technician level. They must know how to implement the local emergency response plan; understand classification, identification, and verification of known and unknown materials using advanced survey instruments and equipment; know the state emergency response plan; select and use proper specialized chemical personal protective equipment; understand in-depth hazard and risk techniques; perform specialized control, containment, and/or confinement operations; determine and implement decontamination procedures; have the ability to develop a site safety and control plan; and understand chemical, radiological, and toxicological terminology and behavior. They provide support to hazardous materials technicians and act as the site liaison with government authorities. [1] [1] [1] [1] [1] [1] [1] [1] [1] [1] [1] [1] [1]

On-Scene Incident Commander

Incident commanders, who assume control of the incident scene beyond the first responder awareness level, must receive at least 24 hours of training equal to the first responder operations level. They must know and be able to implement the employer's incident command system and emergency response plan, understand the hazards and risks associated with employees working in chemical protective clothing, know how to implement the local emergency response plan, know of the state emergency response plan and the Federal Regional Response Team, and understand the importance of decontamination procedures. The employer must certify competency in these areas. [1] [1] [1] [1] [1] [1] [1]

Process Safety Management (PSM) Competencies

Operating Procedures

Operating procedures must describe tasks, data recording, operating conditions, sample collection, and safety and health precautions. They should be technically accurate, understandable, and periodically revised to reflect current safe operations. These procedures should include specific instructions or details on the steps to be taken, including applicable safety precautions and information on safety implications. [4] [4] [4]

Employee Training (PSM)

All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with. Training should cover operating procedures, safety work practices, emergency evacuation and response, safety procedures, and routine and nonroutine work authorization activities. Employers must clearly define the employees to be trained and the subjects to be covered, establishing clear, measurable goals and objectives for the training program. [4] [4] [4]

Contractor Management

Employers using contractors must establish a screening process to ensure contractors perform job tasks without compromising safety and health. This includes obtaining information on injury and illness rates, experience, and references. Employers must also ensure contractors have the appropriate job skills, knowledge, and certifications. A permit system or work authorization system is helpful for controlling contractor activities, especially for specialized and potentially hazardous tasks. [3] [3] [3] [3]

Pre-Startup Safety Reviews

For new processes, a PHA (Process Hazard Analysis) is helpful in improving the design and construction of the process from a reliability and quality point of view. Operating procedures should be in place, and the operating staff trained before startup. Initial startup and normal operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters. [3] [3] [3]

Mechanical Integrity

A mechanical integrity program should be in place to assure the continued integrity of process equipment. Elements of this program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance procedures, training of maintenance personnel, the establishment of criteria for acceptable test results, documentation of test and inspection results, and documentation of manufacturer recommendations as to meantime to failure for equipment and instrumentation. [7] [7]

Nonroutine Work Authorizations

Nonroutine work conducted in process areas needs to be controlled consistently. The hazards identified involving the work must be communicated to those doing the work and to operating personnel whose work could affect the safety of the process. A work authorization notice or permit must describe the steps to obtain the necessary clearance to start the job, referencing lockout/tagout procedures, line breaking procedures, confined space entry procedures, and hot work authorizations. [5] [5] [5] [5]

Managing Change

Changes to process chemicals, technology, equipment, and facilities, other than

"replacement in kind,

" need to be properly managed by identifying and reviewing them before implementation. This includes changes in production rates, raw materials, equipment specifications, and computer program revisions. Temporary changes are subject to the management of change provisions, with a time limit established and monitored to ensure equipment and procedures are returned to their original conditions. [5] [5] [5] [5] [5]

Incident Investigation

Incident investigation involves identifying the underlying causes of incidents and implementing steps to prevent similar events. A multi-disciplinary team should be trained in investigation techniques, including conducting interviews and writing reports. The focus should be on obtaining facts, not placing blame, and the investigation process should be fair, open, and consistent. [5] [2] [2]

Emergency Preparedness

Employers must address actions employees are to take when there is an unwanted release of highly hazardous chemicals. This includes deciding whether employees should handle minor releases, mobilize resources for significant releases, or evacuate the danger area. At a minimum, employers must have an emergency action plan to facilitate prompt evacuation, including support for physically impaired employees. Training should address the needs for employees expected to handle incidental or minor releases. [2] [2] [2] [2]

Firefighter Safety (if applicable)

Employers of firefighters must develop and implement safe work procedures, train firefighters in these procedures, and ensure compliance. These procedures must include firefighting procedures and procedures for responding to other emergencies, such as water rescue and hazardous materials incidents. A system for initiating procedures to protect the safety and health of firefighters at an emergency site and a personnel accountability system must be in place. [10] [10] [9]

PSDI Safety Systems (for Mechanical Power Presses)

The certification/validation of safety systems for PSDI (Presence Sensing Device Initiation) shall consider the press, controls, safeguards, operator, and environment as an integrated system which shall comply with all of the requirements in 29 CFR 1910.217 (a) through (h) and this appendix A. The certification/validation process shall verify that the safety system complies with the OSHA safety requirements. [6] [6]

Design Certification/Validation (PSDI)

The major parts, components, and subsystems used shall be defined by part number or serial number, as appropriate, and by manufacturer to establish the configuration of the system. The identified parts, components, and subsystems shall be certified by the manufacturer to be able to withstand the functional and operational environments of the PSDI safety system. The total system design shall be certified by the manufacturer as complying with all requirements in 29 CFR 1910.217 (a) through (h) and this appendix A. The third-party validation organization shall validate the manufacturer's certification. [6] [6] [6] [6]

Installation Certification/Validation (PSDI)

The employer shall certify that the PSDI safety system has been design certified and validated, that the installation meets the operational and environmental requirements specified by the manufacturer, that the installation drawings are accurate, and that the installation meets the requirements of 29 CFR 1910.217 (a) through (h) and this appendix A. The third-party validation organization shall validate the employer's certifications. [8] [8]

Recertification/Revalidation (PSDI)

The PSDI safety system shall remain under certification/validation for the shorter of one year or until the system hardware is changed, modified or refurbished, or operating conditions are changed (including environmental, application or facility changes), or a failure of a critical component has occurred. Annually, or after a change, the employer shall inspect and recertify the installation. The third-party validation organization, annually or after a change, shall validate the employer's certification. [8] [8] [8]

Record Keeping

The employer must maintain accurate records of all training provided to employees, including the dates of training, the content covered, and the names of the trainers and trainees. For competency demonstrations, the employer must keep a record of the methodology used to demonstrate competency and the results of the assessment. These records are essential for demonstrating compliance with safety regulations and for continuously improving the competency of personnel. [9] [1]

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