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Process Safety Management for Highly Hazardous Chemicals - index
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Questions cont'd - doe-hdbk-1101-20040091


DOE-HDBK-1101-2004
76.
Must written maintenance procedures be specific to each vessel, type of vessel, or
group of equipment types listed?
Maintenance procedures need to be specific to the type of vessel or equipment. Identical
or very similar vessels, and items of equipment in similar service, need not have
individualized maintenance procedures. Each procedure must clearly identify the
equipment to which it applies.
77.
What are process equipment-type controls? Are all controls and interlocks included
in this type, or only the most critical ones?
Process equipment controls are controls, alarms, and interlocks that play a role in
preventing or mitigating the effects of potential catastrophic releases of HHCs to the
workplace. Contractors should consider the importance of each control, alarm, and
interlock in a covered process, as well as the results of PrHAs, in selecting the
appropriate maintenance and inspection procedures and schedules. All process control
equipment is covered. Decisions affect the frequency and nature of the inspection, test,
and preventive maintenance procedures.
78.
Why are some types of process equipment (e.g., compressors, turbines, heat
exchangers, furnaces, scrubbers) left out of the list of items covered under the PSM
Rule?
The PSM Rule does not exclude any equipment within a covered process that is critical
to preventing or mitigating catastrophic releases of HHCs. The equipment listed above
could be included in a generic class called "piping systems and components, pressure
vessels and storage tanks." Contractors should develop lists of such equipment in their
facilities and assess the safety criticality of each item. The assessment should be used to
ensure that maintenance and inspection practices are appropriate in frequency and
comprehensiveness.
79.
Must DOE contractors train subcontract maintenance workers on their
maintenance procedures?
No. Procedures pertinent to subcontractor work must be provided to the maintenance
subcontractor, who is then responsible for training its own workers. However, DOE
contractors are obligated to verify that training has been performed and that subcontractor
workers follow established safe work practices, some of which may be specified in the
written maintenance procedures for covered processes. Some contractors may determine
that it is more efficient for them to train their maintenance subcontractors on unique
process equipment maintenance procedures. In these cases, the training responsibilities of
the two parties should be clearly defined and understood.
74


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