The best you can do is to be sure that your inspection and test program is defendable. Training for Maintenance Activities. In fact, the OSHA compliance directive alerts inspectors to review certification documents for employees performing welding tasks and nondestructive tests. You should already have training requirements in place and some criteria for deciding whether personnel are qualified to perform maintenance activities. PSM gives you the opportunity to formalize these criteria but also makes it necessary for you to document your training program.
Many approaches are possible.
For instance, purchased training packages, in-house shop training, and apprenticeship programs can be useful approaches to initial training. Often, vendors or specialty contractors can help with ongoing training. Be sure that maintenance employees are trained on new equipment as part of the plant's management of change program. Quality Assurance and Equipment Deficiencies. In general, citations that allege violations relating to QA and equipment deficiencies have been issued following accidents.