Across the chemical processing industry, there is a debate on what role supervisors should play during plant upsets and abnormal situations. As plant staffing has been reduced over the last few years, the debate has increased as supervisors are taking on greater upset response responsibilities. At many plants, operators, supervisors, and other management have begun to question the supervisor’s upset response role and how the intended role fits into PSM requirements.
One reoccurring issue is what training do supervisors need to satisfy the PSM requirements (OSHA 29 CFR 1910.119). The ruling reads: “Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job”.
The wording of the ruling is ambiguous; who knows what the statement “Each employee presently involved in operating a process” really means? One interpretation is that since supervisors do not normally have reoccurring hands-on operational responsibilities, the PSM requirements do not include supervisors. If this interpretation is correct, it is the company’s prerogative to set the upset response training requirements for their supervisors.
Training personnel for tasks they do not have to perform is a waste of resources and the trainee’s time. Beville does believe that it is a good operating practice to train supervisors on those tasks they may be called upon to perform during plant upsets. The question is, what are those tasks?
Based upon Beville’s experience, supervisors at plants have been said to perform the following tasks during upsets (the list is in no particular order):
In addition to these items there may be others that management may wish supervisors to perform. It is not unreasonable to expect supervisors to help turn high effort valves under the direction of operators. Ultimately, it is up to management to decide the training their supervisors need for upset response.
With the trend across the chemical processing industry of reducing the number of supervisors, management must critically evaluate the tasks their supervisors are performing. If supervisors are removed or asked to accept greater responsibilities, then management must ensure the consequential tasks the supervisors were performing are still performed by somebody or something (automation).
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