Baseline Audit - doe-hdbk-1101-20040132

DOE-HDBK-1101-2004

ensure that their management of such chemicals conforms to the PSM Rule even though not

required by law.

Baseline Audit

DOE contractors should conduct baseline audits to assess their current degree of compliance

with the PSM Rule. An audit checklist is provided at the end of Section 2.13. Baseline audits

provide a systematic evaluation of internal programs that address individual elements of the

PSM Rule. Because they identify compliance gaps, baseline audits also help in preparing a

strategy for compliance with the PSM Rule.

Implementation Plan

DOE contractors should develop a description of each activity needed to come into compliance

with the PSM Rule. Descriptions must be in sufficient detail to explain exactly what is required.

A written plan should then be developed with specific milestones for completing each activity.

The plan must identify the individuals responsible for developing the overall PSM program and

the lead personnel responsible for each activity.

Employee Involvement

A written plan for employee involvement in the PSM program must be developed. A team

composed of safety personnel, process employees, and process managers should formulate the

plan. If employee involvement programs exist, they should be reviewed to determine if

additional activities are required or desirable, based on requirements in the PSM Rule.

Risk-Based Priorities

For DOE sites with several processes covered under the PSM Rule, completion of PSI and

PrHAs must be prioritized based on risk factors associated with the processes. Risk factors

suggested by the PSM Rule include the extent of the process hazards, the number of potentially

affected employees, the age of the process, and past performance of the process. Other factors

might include the complexity of the process or ratios of quantities of HHCs to their respective

TQs. The prioritized list of processes and the criteria used to rank the processes must be

documented as part of the PSM program records.

Resources and Schedule

The implementation of the PSM Rule at sites with extensive chemical processes may require

additional resources to develop an integrated PSM program. OSHA requires a pre-startup safety

review in addition to a process hazard analysis for new covered facilities and for modified

facilities when the modification is significant enough to require a change in the process safety

information. Additional sources of information regarding PSM program implementation are

provided in Appendix D.

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