OSHA 1910.119 - Process Safety Management

Your next PSM audit starts here.

When an OSHA inspector walks through your gate, can you prove, immediately and on paper, that every operator on every unit is qualified to be there? QualMatrix by OEG connects a structured job-qualification library to a live employee tracking system, giving HSE and operations teams a real-time, auditable view of qualification status across every process unit and operator level.

22
Process units covered
4
Qualification levels
4
Requirement categories
983+
Requirement line items
01 The Problem

Qualification gaps are invisible until an audit or an incident

Most refineries track operator qualifications in spreadsheets, paper files, or disconnected systems. Without a structured framework tied to process-specific requirements, compliance exposure accumulates unseen.

Audit Exposure

OSHA-ready proof is hard to assemble

OSHA 1910.119 requires documented operator competency for every PSM-covered process. Gaps in qualification records are among the most cited findings in refinery PSM audits.

  • High citation frequency
  • MOC and training deficiencies
Operator Turnover

Knowledge leaves faster than systems capture it

Experienced operators retire taking decades of tacit knowledge with them. Without a structured qualification framework, replacement operators are cleared inconsistently and dangerously.

  • Average operator tenure declining
Multi-Site Inconsistency

No shared definition of qualified

Companies operating multiple refineries rarely have a consistent qualification standard across sites. What qualifies a CDU operator at Site A may be meaningless at Site B.

  • No industry-wide standard exists
  • QualMatrix fills the gap
02 Where The Gaps Hide

Risk accumulates in places teams rarely inspect

Risk 01

No Standard Requirements Baseline

Qualification criteria vary by supervisor and site. There is no consistent definition of what an Operator II on the CDU must know versus an Operator II on the FCC until OSHA asks.

Risk 02

No Visibility Into Gaps

Expired training, missing sign-offs, and incomplete checkouts hide in file folders. Supervisors discover gaps reactively, at promotion time or during a compliance audit.

Risk 03

MQO Coverage Unknown Per Shift

Minimum Qualified Operator thresholds must be met every shift. Without real-time tracking, operations managers cannot confirm MQO coverage until someone spots a potential violation.

03 Product

Four components. One qualification platform.

An integrated platform covering the full qualification lifecycle, from defining what operators must know, to tracking who knows it, to planning how they get there, and analyzing cross-unit movement.

Component 01

JQ Reference Tool

A structured, searchable reference covering job-qualification requirements for 22 refinery process units, organized by operator level and qualification category. Every requirement is grounded in PSM, API, and OSHA standards.

Component 02

EMP Tracker

An operator-level tracking system that maps individual employees against qualification requirements, surfaces coverage gaps, and generates the documentation trail needed for audits.

Component 03

Career Progression Tool

A swimlane roadmap showing cumulative qualification requirements from Operator I through Senior, including what is new at each level and what remains outstanding.

Component 04

Decision Tools

Specialized analysis tools: Unit Transfer Analyzer, MQO Checker, and Qualification Matrix for site-wide coverage at a glance.

Component 01 - Reference

JQ Reference Tool

A structured library of qualification requirements covering 22 refinery process units. Organized by operator level and requirement category, it becomes the authoritative standard everything else is measured against.

22 process units4 levelsEDU / EXP / TECH / SARVERIFY dashboard
->
Component 02 - Tracker

EMP Tracker

An employee qualification management system that records completed requirements, computes status against the reference standard, identifies gaps, and supports audit readiness.

Employee profilesGap analysis4 refinery sitesAudit log
04 Component Details

Reference standard plus employee tracking

JQ Reference Tool

The qualification standard for every process unit in your refinery. Each unit page documents the full set of requirements across four operator levels, from entry-level Operator I through Senior Operator, organized into four structured requirement categories.

  • Crude and Vacuum: CDU, VDU
  • Conversion: FCC, Hydrocracker, Delayed Coker, Visbreaker
  • Treating and Upgrading: Hydrotreater, Reformer, ISOM, Alkylation, Merox
  • Utilities: H2 Plant, Amine/SRU, SWS, Cooling Water, Steam and Power
  • Storage and Environmental: Tank Farm, Flare, Wastewater Treatment
  • Specialty: Lube Oil, Asphalt, MTBE/Oxygenates
Unit Page Structure - CDU Example
Requirement
I
II
III
SR
EDU - Education
Process Safety Orientation
Crude Unit Process Fundamentals
-
EXP - Experience
Field Time on CDU (hours)
-
TECH - Technical Knowledge
Distillation Column Checkout
-
SAR - Safety and Administrative
HAZWOPER / PSM Awareness
H2S Safety Certification

Illustrative. Actual requirements vary by unit, level, and site. All values carry site-specific VERIFY flags.

EMP Tracker

The employee-facing half of the platform. Tracks every operator's qualification records against the JQ Reference standard, computes status in real time, and surfaces gaps before they become compliance findings.

  • Employee profiles with KPI tiles and level progression bar
  • Per-requirement status: Current, Expiring (90-day window), Expired, Missing
  • Gap analysis aggregated by unit, site, and operator level
  • Unit Roster view with real-time MQO coverage check
  • Audit log of supervisor sign-off history
  • Career progression: current-level completion vs. full level complement
Employee Profile Summary - Illustrative
87%
Qualified
4
At Risk
2
Gaps
H2S Safety RefresherExpired
FCC Unit CheckoutMissing
HAZWOPER 8-hr RefresherExp in 67d
Distillation Column Emergency OpsExp in 84d

Status computed against all level-applicable requirements across EDU, EXP, TECH, and SAR categories.

05 Key Tools

Purpose-built for operations and compliance teams

Beyond unit pages and employee records, QualMatrix includes cross-cutting tools for qualification management, gap identification, and audit preparation.

JQ Reference

Qualification Matrix

Full cross-unit grid showing requirements for every unit and operator level in a single view. Built for supervisors managing multi-unit operators.

JQ Reference

MQO Checker

Verifies Minimum Qualified Operator coverage per shift and unit. Flags units at risk of falling below the required staffing threshold.

JQ Reference

Progression Roadmap

Maps the qualification path from Operator I through Senior. Shows what is required at each level transition and what remains outstanding.

JQ Reference

Transfer Calculator

Assesses qualification credit when an operator moves between process units. Identifies which requirements carry over and what new training is needed.

JQ Reference

VERIFY Dashboard

Surfaces all site-specific verification flags across the reference library. Identifies requirements that need local SME sign-off before use in compliance decisions.

EMP Tracker

Gap Analysis

Roster-level view of qualification gaps across a unit or site. Prioritized by severity, with expired, missing, and at-risk items surfaced separately.

06 Workflow

From requirement to audit evidence

Three steps from opening the tool to knowing exactly where your qualification gaps are.

1

Select Your Unit

Navigate to any of 22 covered process units: CDU, FCC, Hydrocracker, Reformer, Coker, and more.

2

Filter by Level

Toggle between Operator I through Senior to see the specific qualification requirements for that role.

3

Track and Document

Map real operators against requirements in the EMP Tracker. Export gap reports for audit packages.

07 Qualification Framework

Levels, categories, and status determination

Every qualification decision in QualMatrix is built on the same four-level, four-category framework, applied consistently across all 22 process units.

Qualification Levels
Level 01

Operator I

Entry level. Basic process knowledge, safety orientation, and supervised field time on unit.

Level 02

Operator II

Independently operates the assigned unit. Demonstrated process knowledge and emergency response competency.

Level 03

Operator III

Cross-unit qualified. Lead operator capable of training others and managing complex abnormal situations.

Level 04

Senior Operator

Full process mastery. Qualifies to act as unit authority, mentor Op III operators, and support PSM documentation.

Requirement Categories
EDU

Education

Formal training, courses, and certifications, including initial qualification and periodic refresher requirements with expiry tracking.

EXP

Experience

Documented field time on unit. On-the-job training sign-offs and time-in-position requirements verified by supervisor.

TECH

Technical Knowledge

Unit-specific process knowledge assessments, equipment checkout sign-offs, and demonstrated competency verification.

SAR

Safety and Admin

Safety certifications, procedural compliance items, and administrative sign-offs required by OSHA standards and site policy.

Status Determination Logic
Qualified

All level-applicable requirements across all four categories are current. No missing, expired, or at-risk items present.

At Risk

All requirements are present and current, but one or more expire within 90 days. Renewal action required before expiry.

Not Qualified

One or more requirements are missing or expired. Not qualified regardless of completion percentage because all requirements must be current.

08 Unit Coverage

22 process units. Every major refinery area.

Coverage spans crude processing through treating and utilities: the full breadth of a complex refinery operation.

Crude and Vacuum
Crude Distillation Unit
Vacuum Distillation Unit
Visbreaker
Asphalt Unit
Conversion
Fluid Catalytic Cracker
Hydrocracker
Delayed Coker
Lube Oil Complex
Treating and Hydro
Hydrotreater
Amine / SRU
Sour Water Stripper
Merox Treating
Reforming and Light Ends
Catalytic Reformer
Isomerization
Alkylation
MTBE Unit
Utilities and Offsites
H2 Plant
Steam and Power
Cooling Water
Flare Systems
Tank Farm
Transfer / Pipeline
Wastewater Treatment
09 Regulatory Grounding

Built on the standards auditors use

Every qualification requirement is grounded in or cross-referenced to recognized standards. This is not a generic training checklist; it is a PSM-aligned documentation framework.

The platform addresses the operator competency requirement embedded in OSHA 1910.119, specifically the Training element (§1910.119(g)) and Employee Participation requirement (§1910.119(c)). Requirements are also informed by API standards governing process hazards: HTHA, REAC circuit corrosion, fired heater operations, and reactive chemistry.

OSHA 1910.119 (PSM)API 941API 932-A/BAPI 560API 751NFPA 86EPA RMP 40 CFR Part 68
§(g)

Training

Documents initial and refresher training completion per unit and operator level. Tracks frequency and expiry against defined intervals.

§(e)

Operating Procedures

Links qualification requirements to unit-specific operating procedures and supports procedure review sign-off tracking.

§(j)

Mechanical Integrity

Technical qualification requirements capture equipment-specific competency verification for MI program documentation.

§(l)

Management of Change

VERIFY flags identify qualification items requiring SME confirmation when process changes occur.

MQO

Minimum Qualified Operators

MQO Checker and Unit Roster tools provide shift-level visibility into qualified staffing thresholds.

Audit

Audit Readiness

VERIFY Dashboard, Gap Analysis, and employee profiles provide the documentation trail required during a PSM compliance audit.

10 Product Roadmap

Where we've been. Where we're going.

We build in the open. Here is what is already shipped and what is coming next, so you can plan accordingly and influence what gets prioritized.

Already Delivered

JQ Reference Tool - 22 Units Shipped

Full qualification requirements for every major refinery process unit, organized by operator level and category.

EMP Tracker - Gap Analysis Shipped

Roster management, per-unit tracking, cert expiry monitoring, and single-point-of-failure identification.

Career Progression Roadmap Shipped

Visual swimlane showing cumulative requirements from Operator I through Senior.

Unit Transfer Analyzer Shipped

Maps qualification overlap when moving operators between units.

MQO Checker Shipped

Instant check of whether a unit meets minimum staffing requirements by level before shift handover.

Qualification Matrix Shipped

Site-wide coverage view: all units by all operator levels in a single grid.

Supervisor Sign-Off Workflow High Priority

Supervisors review, attest, and sign off on operator competency records.

Audit Export Package High Priority

One-click PDF/CSV export of operator qualification status by unit.

MOC-Triggered Requalification High Priority

Automatically flags affected operators for requalification when a procedure or process change is logged.

🔐

User Authentication and Roles High Priority

Role-based access for Admin, HSE, Supervisor, and Operator with site-level data isolation.

🏭

Site-Specific Customization Medium

Override generic defaults with site-specific requirements.

LMS / HR Integration Medium

API connections to LMS and HR systems such as Cornerstone, SuccessFactors, and Workday.

Mobile-Optimized Interface Medium

Control room and field-accessible mobile view for shift teams.

11 Pricing

Scaled to your operation.

Pricing is site-based and aligned with refinery budgets. No per-user fees, no seat counting. One annual rate per facility, with volume discounts for multi-site operators.

Tier 02

Multi-Site

Expanding from a successful pilot. Standard annual rate per site, with volume pricing as your fleet grows.

  • All platform modules across every site
  • Centralized multi-site roster management
  • Cross-site gap analysis and benchmarking
  • Annual contract, multi-year preferred
  • Volume discount at 5+ sites
Tier 03

Enterprise Fleet

For companies operating large refinery networks. Custom contract structure, fleet analytics, and priority access to roadmap features.

  • Everything in Multi-Site
  • Fleet-level qualification dashboard
  • LMS / HR integration roadmap
  • Custom qualification standard configuration
  • Dedicated account management
Onboarding note: Pilot pricing includes data onboarding support for rosters up to 75 operators. Larger rosters, common at complex refineries, are scoped separately. Contact us for a scoped estimate before your first site goes live.
12 Getting Started

From conversation to live in weeks.

No lengthy procurement cycles or implementation projects. The pilot is designed to be running on real data within two to three weeks of a go-ahead.

1

Conversation

We understand your current qualification tracking state, unit coverage, and operator roster size.

2

Configuration

We configure qualification standards to reflect your site's units, operator levels, and site-specific requirements.

3

Data Load

We load your operator roster and existing qualification records into the platform.

4

Go Live

Your team has access. Gap analysis is immediate. Audit-ready documentation is available from day one.

13 Pilot

Ready to see it on your data?

Request a pilot or ask about implementation

We're currently running a small number of pilot sites at preferred pricing in exchange for feedback and a reference. If your site runs any PSM-covered process units, you qualify.

Address
10235 West Little York Road, Suite 260
Houston, TX 77040 USA
Phone
+1 281.794.9107
Email
sales@oegllc.com
Request Pilot
Complete the form and we will get back to you.