Most DOE contractors have hazard communication programs that use information from
Materials Safety Data Sheets (MSDSs) to comply with 29 CFR 1910.1200. Information about
the hazards posed by most process chemicals may also be obtained from MSDSs. Additional
information may be required to describe process chemistry conditions that can lead to
overpressures or runaway reactions. DOE information requirements regarding hazard
identification are included in DOE O 151.1B, COMPREHENSIVE EMERGENCY
MANAGEMENT SYSTEM, DOE O 420.1A FACILITY SAFETY, DOE O 430.1B, REAL
PROPERTY ASSET MANAGEMENT, and DOE O 440.1A, WORKER PROTECTION
MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES.
Some DOE facilities, especially nuclear facilities, have design information for systems,
structures, and components to support Safety Analysis Reports (SARs) and ongoing engineering
improvements to systems. Systems for maintaining as-built drawings of processes, together with
their original design basis and history of modifications, may be available for these facilities.
However, documentation of the design basis for older DOE facilities and nonnuclear facilities is
New DOE facilities are required under DOE O 430.1B to meet certain facility safety
requirements. SARs for existing facilities require that the facility design be evaluated for
conformance with these requirements. Statements in the design information and/or the SAR
regarding compliance with these safety design requirements provide documentation that facilities
and equipment are designed in accordance with recognized and generally accepted good
engineering practices. DOE information requirements associated with the technology and
equipment of a nuclear process are found in 10 CFR 830 Subpart B, NUCLEAR SAFETY
MANAGEMENT, SAFETY BASIS REQUIREMENTS.
The PSI element is a documentation requirement. It specifies the minimum written PSI package
needed to support a PSM program. It should be updated as part of the MOC element of the PSM
Rule because the safety of processes depends on workers having access to accurate process
safety information. PSI used to support the development of facility safety documentation or
PrHAs should be referenced. PSI need not be located in one document or in one place [Q42].
Electronic storage media may be used so long as a backup version is available at all times [Q44].
PSI should be part of the facility configuration information and should be maintained for the life
of a process through a configuration management system [Q45].
Complete PSI packages are essential for conducting PrHAs. Initial PSI is required to establish
risk-based priorities for completion of PrHAs.
Minimum Implementation Criteria
Adequate information must be available to support preparation of PrHAs, operating procedures,
training materials, and emergency plans. The PrHA team can generate information on process
technology when complete information does not exist. In addition, documentation must be
available to confirm that process equipment complies with recognized and generally accepted