ensure that their management of such chemicals conforms to the PSM Rule even though not
required by law.
DOE contractors should conduct baseline audits to assess their current degree of compliance
with the PSM Rule. An audit checklist is provided at the end of Section 2.13. Baseline audits
provide a systematic evaluation of internal programs that address individual elements of the
PSM Rule. Because they identify compliance gaps, baseline audits also help in preparing a
strategy for compliance with the PSM Rule.
DOE contractors should develop a description of each activity needed to come into compliance
with the PSM Rule. Descriptions must be in sufficient detail to explain exactly what is required.
A written plan should then be developed with specific milestones for completing each activity.
The plan must identify the individuals responsible for developing the overall PSM program and
the lead personnel responsible for each activity.
A written plan for employee involvement in the PSM program must be developed. A team
composed of safety personnel, process employees, and process managers should formulate the
plan. If employee involvement programs exist, they should be reviewed to determine if
additional activities are required or desirable, based on requirements in the PSM Rule.
For DOE sites with several processes covered under the PSM Rule, completion of PSI and
PrHAs must be prioritized based on risk factors associated with the processes. Risk factors
suggested by the PSM Rule include the extent of the process hazards, the number of potentially
affected employees, the age of the process, and past performance of the process. Other factors
might include the complexity of the process or ratios of quantities of HHCs to their respective
TQs. The prioritized list of processes and the criteria used to rank the processes must be
documented as part of the PSM program records.
Resources and Schedule
The implementation of the PSM Rule at sites with extensive chemical processes may require
additional resources to develop an integrated PSM program. OSHA requires a pre-startup safety
review in addition to a process hazard analysis for new covered facilities and for modified
facilities when the modification is significant enough to require a change in the process safety
information. Additional sources of information regarding PSM program implementation are
provided in Appendix D.