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Table 1.1 Overview of PSM Elements - doe-hdbk-1101-20040018
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Process Safety Management for Highly Hazardous Chemicals - index
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Figure 1.1 Chemical Safety Programs Related to Accident Consequence - doe-hdbk-1101-20040020


DOE-HDBK-1101-2004
Table 1.1 Overview of PSM Elements (Continued)
Incident Investigation
Using a written procedure, provide a team investigation of
any incident which results in, or could reasonably result in,
a catastrophic release of a highly hazardous chemical. Each
investigation must be documented in a written report and
findings and recommendations resolved in a timely manner.
Emergency Planning and Response Establish and implement an emergency action plan for the
entire plant that complies with 29 CFR 1910.38(a) and that
also addresses small releases.
Compliance Audit
Ensure that the PSM program is operating in an integrated
and effective manner in compliance with PSM
requirements.
Trade Secrets
Ensure all information is available to support the PSM
Rule. When necessary, confidentiality or nondisclosure
agreements may be used.
The new pressure relief system must be inspected and tested (Mechanical Integrity) and all
factors for safe operation must be reviewed (Pre-startup Safety Review [PSR]) before that
portion of the process is brought back on line. The piping and instrumentation diagrams (P&IDs)
and other engineering drawings must be revised to show the as-modified configuration of the
system (PSI). The rationale and information about the changes must be available for review by
employees and their representatives (Employee Involvement). Using this information, the PrHA
is updated to account for potential hazards associated with the new equipment. Also, inspection
and maintenance procedures and training must be updated (Mechanical Integrity, Operating
Procedures, Training).
The PSM Rule is a performance-based rule; it does not prescribe how each element is to be
implemented. Therefore, this Handbook has been developed to suggest an approach to
effectively implement the elements of this Rule within DOE. Relevant excerpts of the Rule are
provided with the discussion of each element, and the complete text is provided in Appendix B.
In addition, the discussion of each element concludes with questions and answers taken from
OSHA's interpretation of the Rule in response to industry and labor inquiries. Appendix C
compares the elements of the PSM Rule with the provisions of EPA's Risk Management
Program.
Note that the function of PSM differs from that of DOE Safety Analysis Reports (SARs). Hazard
analyses are conducted during the SAR process to identify potential accident scenarios whose
risks are assessed to determine whether designs, controls, and limits are sufficient to ensure that
a DOE facility can be operated safely in a manner that adequately protects workers, the public,
and the environment. Unmitigated releases are compared against the evaluation guidelines to
determine whether they challenge those guidelines. PrHAs are conducted to identify all process
hazards and to evaluate the adequacy of control measures for each hazard. As discussed in
3


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