TRAINING DOCUMENTATION GAPS = #1 PSM CITATION
PSM Training Compliance
OSHA 29 CFR 1910.119 training requirements explained in plain English — and exactly how our AI system satisfies every one of them.
This section requires employers to train each employee presently involved in operating a process and each employee before being involved in a newly assigned process. Training must cover the process overview, operating procedures, specific safety and health hazards, emergency operations, and safe work practices.
Initial Training
Before assignment to a covered process
Our Level 1-3 curriculum covers all required topics. No operator accesses a unit without completing unit-specific training first.
Refresher Training
At least every 3 years
Automated cycle tracking with refreshed content reflecting current procedures, recent incidents, and regulatory changes.
Means to Verify Understanding
Not just attendance — comprehension must be verified
Every module includes scored assessments with 80% minimum passing score. Failed items trigger retraining.
Documentation
Employee identity, date, and verification method
Auto-generated completion records with employee name, date, assessment type, score, pass/fail, and topics covered.
This section requires each employee involved in maintaining the on-going integrity of process equipment to be trained in an overview of the process, its hazards, and the procedures applicable to the employee’s job tasks.
Process Overview & Hazards
Mechanics must understand the process they maintain
Level 1 covers refinery safety and process hazards. Level 2-3 covers equipment-specific hazards with API/ASME code references.
Job Task Procedures
Procedures applicable to the employee’s specific tasks
Every Level 3 module includes step-by-step Job Task Procedures with WARNING/CAUTION callouts, PPE requirements, and acceptance criteria.
Equipment Categories
Vessels, piping, relief systems, controls, pumps, compressors
Dedicated training modules for every MI equipment category with appropriate API, ASME, and NBIC standard references.
Inspection & Testing
Written procedures for inspection and test frequencies
Level 4 covers NDE methods, corrosion mechanisms, and predictive maintenance technologies.
Contract employers must assure each contract employee is trained in work practices necessary to safely perform their job, instructed in known potential fire, explosion, or toxic release hazards, and understands the emergency action plan.
Safe Work Practices
Training for specific work being performed
Configurable contractor orientation modules tailored to the scope of work (hot work, confined space, elevated work, etc.).
Hazard Awareness
Known fire, explosion, toxic release hazards
Site-specific hazard briefings generated from facility PHA data. Includes H2S, hydrocarbon, and chemical-specific hazards.
Emergency Action Plan
Applicable EAP provisions
Unit-specific emergency response training covering evacuation routes, muster points, alarm types, and shelter-in-place.
Contractor Documentation
Same 3-element record: identity, date, verification
Auto-generated completion records for contractor employees. Scalable to 5,000+ turnaround contractors.
OSHA Penalty Schedule (2025 Rates)
Penalties are adjusted annually for inflation. Training documentation gaps are the #1 most cited PSM violation.
$16,550
Serious Violation
Per violation instance
$165,514
Willful or Repeated
Per violation instance
$16,550
Failure to Abate
Per day of non-compliance
$0
With Porritt Inc.
Compliant from day one
Sample Training Completion Record
Every training module auto-generates this OSHA-compliant record. No manual paperwork. No gaps.
TRAINING COMPLETION RECORD — Porritt Inc. AI Training System
Employee Name: John Martinez
Employee ID: OP-2024-0847
Department/Unit: FCC Unit — Operations
Date of Training: March 24, 2026
Training Module: 3.3 — FCC Unit Operations
OSHA Reference: 29 CFR 1910.119(g)
Score: 90%
Result: PASS (minimum 80%)
Download the PSM Training Compliance Checklist
A complete checklist mapping every OSHA 1910.119 training requirement to our system’s compliance features. Free, no obligation.
Request the Checklist