Intent - doe-hdbk-1101-20040044

DOE-HDBK-1101-2004

(6)

At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis

shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure

that the process hazard analysis is consistent with the current process.

(7)

Employers shall retain process hazards analyses and updates or revalidations for each process covered by this

section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for

the life of the process.

Intent

PrHA is a systematic method to identify and assess process hazards, and is the cornerstone of a

PSM program. PrHAs can be used to identify causes and consequences of potential accidents

associated with equipment, instrumentation, utilities, human performance, external factors, and

natural phenomena such as earthquakes. The objective of PrHA is to determine areas of

excessive risk where preventative and mitigative measures may be warranted to better control

the hazards. PrHAs can help identify accident scenarios leading to worker injuries or fatalities,

property damage, public exposure to chemicals, environmental impacts, or other adverse

consequences.

Corresponding DOE Programs and Requirements

General Guidance DOE-HDBK-1100-96, Chemical Process Hazards Analysis, provides detailed

information on PrHA methodologies and the PrHA process. DOE guidance available to support

the process hazard analysis team includes DOE/EH-0340, Example Process Hazard Analysis of a

Department of Energy Water Chlorination Process.

Safety Analyses DOE O 430.1B, REAL PROPERTY ASSET MANAGEMENT, requires a

preliminary safety assessment as part of the project management system prior to execution of

design plans. DOE requires that hazard analyses be performed to support SARs under 10 CFR

830 Subpart B NUCLEAR SAFETY MANAGEMENT, SAFETY BASIS REQUIREMENTS

and DOE-STD-1027-92 (CH-1). PrHAs will not replace SARs, nor will SARs replace PrHAs;

they are conducted to satisfy two independent sets of requirements. Therefore, conduct of a

PrHA does not necessarily mean that a SAR must be performed or vice versa. However, because

a PrHA is a systematic method to identify accident scenarios, it may be used as an integral part

of the overall hazards analysis required in the development of a SAR, when a SAR is necessary.

When the PrHA is used to support the SAR, all PSM documents used to develop the PrHA

should be referenced in the appropriate SAR chapter. References and summaries should include

not only the results of the PrHA, but also all documents concerning the resolution of the PrHA

OSHA requires that PrHAs address facility sitting issues (e.g., the physical spacing between

processes, or between a process and administrative facilities). Consideration of natural

phenomenon hazards is also an appropriate sitting issue, especially for new proposed facilities.