Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

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 processes.

52.

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.

53.

What minimum documentation is required in a PrHA report?

Because the PSM Rule is primarily a performance-based regulation, no prescriptive documen-

tation 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.

54.

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?

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 consistent way. DOE

contractors must document their prioritization of processes for PrHA.

55.

What rationale must DOE contractors use to determine the priority for conducting

PrHAs? Should the rationale include age, history, and extent of employee exposure?

The appropriate priority for conducting PrHAs must be determined using all of the criteria

identified in this paragraph, i.e., the extent of the process hazards (catastrophic potential), the