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.
What training/experience is necessary for a member of the PrHA team to be
considered knowledgeable in the selected PrHA methodology? What documentation
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.
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.
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.
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