Do DOE contractors have to create a written procedure for every job function or
task that an operator performs, or only the most important ones?
The PSM Rule specifies the phases of operation for which written procedures are
required. However, it does not specify the job tasks necessary within each operating
phase. Contractors may determine if job functions and tasks need detailed, step-by-step,
written procedures. For example, in some cases detailed procedures for drawing
laboratory samples from processes may be needed to train employees to safely conduct
sampling tasks. In other cases, sampling tasks may not present any hazard to a worker,
and a detailed written procedure would not be necessary.
If an existing process has already undergone initial startup (e.g., after an emergency
shutdown, or turnaround), must a written procedure for initial startup be developed
in addition to procedures for other types of startups?
DOE contractors should have operating procedures for every type of startup expected
during the life of a process. Many contractors will use the initial startup procedure for
startups following major turnarounds or long outages. If a particular phase of operation
specified in the PSM Rule is not relevant to a process, contractors should document this
Does control measures to be taken if physical contact or airborne exposure occurs
refer to first aid, or industrial hygiene services?
The term control measures refers to first aid procedures or emergency medical attention,
which should be consistent with the information on material safety data sheets.