team should consider how close a covered process is to workers or high traffic areas
when evaluating the potential safety and health impacts of possible releases of HHCs.
Possible facility siting issues include the location of vessels containing HHCs and their
proximity to other equipment, control rooms, maintenance shops, and administration
Human factors is a broad classification of issues and techniques dealing with the
functional relationship between human operators and engineered systems. In a PrHA,
human factors could include listing potential human-error causes of accidents; examining
the location of and access to critical safety instruments, alarms, and equipment; or
reviewing critical procedures used by operators and maintenance personnel.
DOE Contractors should examine the specific needs of each covered process to
determine an appropriate way to address facility siting, human factors, and other issues in
a PrHA. These issues need not be addressed at the same level of detail for all covered
The PSM Rule requires that employers promptly address the problems identified in
the PrHA in a timely manner, and complete actions as soon as possible. What time
frame is intended here?
As soon as possible means that DOE contractors must proceed with all due speed,
considering the complexity of the recommendation and the difficulty of implementation.
OSHA expects employers to resolve PrHA team recommendations promptly; normally
within weeks to a few months. DOE contractors should develop a schedule for
completion of any corrective actions expected to require more than three months to
implement and to document the basis for the extended time needed.
What minimum documentation is required in a PrHA report?
Because the PSM Rule is primarily a performance-based regulation, no prescriptive
documentation requirements have been established for PrHAs. Contractors should
include sufficient information to show that the required issues in paragraph (e)(3) of the
Rule have been addressed. For example, the report should identify the PrHA team
members, the process analyzed, the selected PrHA method used, the manner in which the
required PrHA issues were addressed, and the recommendations from the study. Other
documentation to support the review depends on the method selected, the process
analyzed, and the particular needs of the facility.
Can a company prioritize the PrHAs to be performed on a company-wide basis
instead of a site-specific basis? Can a large processing complex be divided into
several logical systems for the purpose of applying the phase-in provisions for initial
PrHAs must be prioritized on a site-by-site basis. When PrHAs are performed on similar
processes, DOE contractors may order these analyses to make the best use of their
experience. A large, processing complex consisting of several discrete systems (e.g.,
feed, reaction, purification, storage) or containing several different HHCs may be divided
into logical separate processes as long as this division is performed in a technically