Background - doe-hdbk-1101-20040021

DOE-HDBK-1101-2004

Section 2.3, PrHAs may be used to support development of SARs. SARs may incorporate

information on many or all PSM elements. However, the minimum requirements for the PSM

Rule must be met if the SAR is to be the source of PSM documentation for a covered process.

1.2 Background

Historically, chemical process hazards within the DOE complex have been considered relatively

minor compared to nuclear hazards. Prior to the promulgation of the PSM Rule, HHCs were

generally viewed as standard industrial hazards unless they could potentially affect the nuclear

inventory of a facility. Thus, consideration of chemical releases in safety analysis documents is a

relatively recent practice within DOE. DOE policies and Orders have not provided an integrated

approach to chemical process safety management. While some PSM elements were in place

within DOE, they were designed for nuclear rather than chemical process safety.

The PSM Rule, which was issued February 24, 1992, addresses chemical process hazards by

redefining the minimum management program requirements for quantities of certain HHCs that

equal or exceed specified threshold quantities (TQs). DOE O 440.1A, WORKER PROTECTION

MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, requires that

covered chemical processes within DOE comply with the PSM Rule. In June 2004 the DOE sent

the Office of Management and Budget, DRAFT 10 CFR 851 "Worker Safety and Health" for

subsequent publication in the Federal Register as the new DOE Worker Safety and Health Rule.

This new Rule will require contractors to follow all applicable portions of 29 CFR 1910. Where

DOE contractors have processes covered by the PSM Rule, all PSM elements must be in place

prior to process startup. The PSI and PrHA elements must be updated and revalidated at least

every five (5) years after the completion of the initial process hazard analysis to assure that the

process hazard analysis is consistent with the current process. Refresher training and compliance

audits must be completed at least every three years following the initial refresher training and

audits.

1.3 Application

The PSM Rule applies to "processes" rather than to "plants" [Q1, Q2, Q3]. The definition of

process given in the glossary indicates that chemical quantities in distinct and separate processes

may be compared individually, rather than collectively, to the threshold quantity (TQ) [Q4,

glossary definition of process]. The PSM Rule applies to any process that meets the following

criteria.

The process contains the specified TQ or more, by weight, of any of the 137 listed HHCs

[Q5, Q6, Q7]. (OSHA's toxic and reactive HHCs and their respective TQs are provided

in Appendix A.)

The process contains 10,000 pounds or more of a flammable HHC (liquid or gas, or

mixture of flammable liquids or gases) [Q8, Q9], in one location, with the following

exceptions.