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Figure 1.1 Chemical Safety Programs Related to Accident Consequence - doe-hdbk-1101-20040020
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Process Safety Management for Highly Hazardous Chemicals - index
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Application cont'd - doe-hdbk-1101-20040022


DOE-HDBK-1101-2004
Section 2.3, PrHAs may be used to support development of SARs. SARs may incorporate
information on many or all PSM elements. However, the minimum requirements for the PSM
Rule must be met if the SAR is to be the source of PSM documentation for a covered process.
1.2 Background
Historically, chemical process hazards within the DOE complex have been considered relatively
minor compared to nuclear hazards. Prior to the promulgation of the PSM Rule, HHCs were
generally viewed as standard industrial hazards unless they could potentially affect the nuclear
inventory of a facility. Thus, consideration of chemical releases in safety analysis documents is a
relatively recent practice within DOE. DOE policies and Orders have not provided an integrated
approach to chemical process safety management. While some PSM elements were in place
within DOE, they were designed for nuclear rather than chemical process safety.
The PSM Rule, which was issued February 24, 1992, addresses chemical process hazards by
redefining the minimum management program requirements for quantities of certain HHCs that
equal or exceed specified threshold quantities (TQs). DOE O 440.1A, WORKER PROTECTION
MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, requires that
covered chemical processes within DOE comply with the PSM Rule. In June 2004 the DOE sent
the Office of Management and Budget, DRAFT 10 CFR 851 "Worker Safety and Health" for
subsequent publication in the Federal Register as the new DOE Worker Safety and Health Rule.
This new Rule will require contractors to follow all applicable portions of 29 CFR 1910. Where
DOE contractors have processes covered by the PSM Rule, all PSM elements must be in place
prior to process startup. The PSI and PrHA elements must be updated and revalidated at least
every five (5) years after the completion of the initial process hazard analysis to assure that the
process hazard analysis is consistent with the current process. Refresher training and compliance
audits must be completed at least every three years following the initial refresher training and
audits.
1.3 Application
The PSM Rule applies to "processes" rather than to "plants" [Q1, Q2, Q3]. The definition of
process given in the glossary indicates that chemical quantities in distinct and separate processes
may be compared individually, rather than collectively, to the threshold quantity (TQ) [Q4,
glossary definition of process]. The PSM Rule applies to any process that meets the following
criteria.
 The process contains the specified TQ or more, by weight, of any of the 137 listed HHCs
[Q5, Q6, Q7]. (OSHA's toxic and reactive HHCs and their respective TQs are provided
in Appendix A.)
The process contains 10,000 pounds or more of a flammable HHC (liquid or gas, or
mixture of flammable liquids or gases) [Q8, Q9], in one location, with the following
exceptions.
5


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