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Process Safety Management for Highly Hazardous Chemicals - index
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DOE-HDBK-1101-2004
specified to define remote. DOE contractors should review each situation and document
their technical bases for determining whether a process is exempt. No accident at a
remote location should have the potential to injure people at locations which are normally
occupied.
23.
What documentation is needed, if any, to support a DOE contractor's judgment that
a particular site, facility, or process is not covered?
No specific documentation is required by the PSM Rule concerning the establishment of
covered processes. However, DOE contractors should maintain a list of covered
processes and document the technical basis for any decision to exclude a process from
coverage where the PSM Rule is subject to interpretation.
24.
Single containers used to store a specific HHC, each containing less than the TQ
amount, are located at several distinct, widely-separated locations in a plant. Is the
storage and handling of this HHC covered under the Rule if the combined amount
of two or more containers exceeds the TQ for the HHC?
If the containers are not connected and are not in one location, then each container and its
associated process should be evaluated separately. On the other hand, if widely separated
containers are connected by process piping, and a loss of containment in one section
could cause an HHC to be released from more than one container, then coverage should
be evaluated on the basis of the total amount of HHC in all of the connected containers.
A similar argument applies if these separate containers, although unconnected, are all
stored in one location where a single, common event could release the HHC from two or
more containers.
25.
Does the PSM Rule apply to onsite movement of HHCs in containers, trucks, or
railcars?
The PSM Rule applies to the onsite movement and storage of HHCs in containers or
vehicles operated by employees. Onsite and offsite movement of HHCs by commercial
carriers is regulated by other agencies such as the U.S. Department of Transportation
(DOT), the Office of Pipeline Safety, and the U.S. Coast Guard.
For example, a railroad tank car is subject to PSM requirements if it contains more than
the TQ of an HHC. However, the exception for flammable liquids stored in atmospheric
tanks or transferred below their normal boiling point without the benefit of chilling or
refrigeration may apply so long as the rail car is not pressurized.
26.
A process contains a material not covered by the PSM Rule. However, release of this
material to the atmosphere in sufficient amounts would generate (e.g., through
oxidation, fire, reaction with moisture, etc.) an HHC in excess of its TQ. Is this
process covered?
A process is not covered under the PSM Rule unless it contains an HHC that exceeds its
TQ. However, when DOE contractors recognize situations with significant potential
impacts to workers, the public, the environment, or facilities and operations; they should
consider applying appropriate PSM safety management elements.
12


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