Questions - doe-hdbk-1101-20040048

DOE-HDBK-1101-2004

Questions

47.

What characteristics does an "appropriate equivalent methodology" need to be

considered acceptable for performing a PrHA?

Any technique or combination of techniques used to perform a PrHA must address the

issues specified in this provision (e.g., the extent of hazards, the qualitative description of

range of consequences). Moreover, the methods should generate the types of results and

documentation required by the Rule (e.g., a list of recommendations). Beyond these

criteria, a PrHA method should help ensure a thorough evaluation of potential safety and

health impacts from process equipment failures and human errors.

48.

What training/experience is necessary for a member of the PrHA team to be

considered knowledgeable in the selected PrHA methodology? What documentation

is required?

Knowledge of the PrHA method selected for use for a particular process is required for

only one member of the PrHA team. There are no specific requirements for PrHA

qualifications or for documenting the qualifications of PrHA team members. Detailed

hands-on classroom training on PrHA methods is an appropriate way for team members

to gain necessary knowledge of a specific PrHA method. Previously demonstrated

experience in the use of the technique may also be accepted as sufficient "qualification"

for PrHA team leaders. Contractors may elect to compile a list of PrHA-qualified

individuals at a facility along with their PrHA experience.

49.

If batch processes involve hundreds of recipes and chemicals, must a separate PrHA

be performed on each recipe, or can these PrHAs be done generically?

PrHAs for batch processes that use a variety of chemicals and recipes can be performed

on a generic basis as long as the chemicals and recipes represent the full range of possible

processing circumstances, including worst case situations. The technical basis for this

worstcase selection of circumstances should be documented.

50.

Is identification of previous incidents restricted to the specific facility or must DOE

contractors conduct an industry-wide search for incident information?

The PSM Rule requires DOE contractors to address in the PrHA previous incidents at

their facilities that had a reasonable potential for catastrophic effects in the workplace.

Although there are no requirements to consider incidents that occurred outside a facility,

DOE contractors should review relevant incidents that have occurred elsewhere in their

company, in the DOE complex, or in industry.

51.

How should facility sitting and human factors be addressed in a PrHA?

Facility siting means the location of covered processes within the plant property. A PrHA