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Process Safety Management Elements - doe-hdbk-1101-20040031
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DOE-HDBK-1101-2004
2.1 Employee Participation
29 CFR 1910.119 (c)
(1) Employers shall develop a written plan of action regarding the implementation of the employee participation
required by this paragraph.
(2) Employers shall consult with employees and their representatives on the conduct and development of
process hazards analyses and on the development of the other elements of process safety management in this
standard.
(3) Employers shall provide to employees and their representatives access to process hazard analyses and to all
other information required to be developed under this standard
Intent
Recent enforcement actions indicate that OSHA expects employers to consult with employees
and their representatives on each PSM element (including development of the employee
participation plan) [Q36, Q37]. Employees with a working understanding of chemical processes
should serve as informational resources in the development of chemical process accident
prevention plans, the performance of PrHAs, and the conduct of incident investigations and
audits. As a minimum, employees and their representatives must be consulted (i.e., information
exchanged and input solicited) [Q38, Q39]. The effectiveness of PSM programs depends on the
employees' sense of ownership and accountability.
DOE contractors should work with employees and their representatives to reach agreement on
and to document the optimum level of employee involvement for each element. Contractors must
also ensure that workers have access to PrHAs and PSI to promote the safety of day-to-day
operations [Q40, Q41].
Corresponding DOE Programs and Requirements
General areas for employee participation in DOE safety and health programs are identified in
DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND
CONTRACTOR EMPLOYEES.
Documentation Requirements
Contractors are required to prepare written plan for worker involvement. The plan must address
the minimum requirements for consultation on development of PrHAs and other PSM elements.
It must also address worker access to PrHAs, PSI, and all documentation developed under the
PSM Rule. A sample employee involvement program is included at the end of this section in
Exhibit 2.1.
Minimum Implementation Criteria
DOE contractors must develop a plan that provides for an appropriate level of employee
participation in the conduct of each PSM element (e.g., consultation with workers on PrHAs,
employee access to PrHAs and PSI, and training).
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