Corresponding DOE Programs and Requirements cont'd

DOE-HDBK-1101-2004

To instill a sense of ownership, each operator may be assigned a portion of procedures to

develop, review, and maintenance, even if the first draft of the procedures is written by someone

else. This approach is not intended to preclude other workers from writing or amending

procedures. Rather, it ensures that someone takes responsibility for their accuracy, timely

completion, and current applicability.

Corresponding DOE Programs and Requirements

DOE O 5480.19 Chg 2, CONDUCT OF OPERATIONS REQUIREMENTS FOR DOE

FACILITIES, and DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE

FEDERAL AND CONTRACTOR EMPLOYEES, contain provisions for written operating

procedures. Operating procedures for processes covered by the PSM Rule should be reviewed to

ensure that they comply with these requirements. Safe work practices should be reviewed to

ensure that they are current. Additional safe work practices may need to be developed if PrHAs

identify frequently encountered hazards that are not unique to a given process. Additional DOE

guidance is provided in DOE-STD-1029-92 (CH-1), Writer's Guide for Technical Procedures.

Documentation Requirements

If operators are to work safely and efficiently, they must understand the reasons for the actions

described. Therefore, operating procedures for chemical processes covered by the PSM Rule

should describe operator interactions with process units, explaining why actions are to be carried

out in the manner described. Generally, procedures should be written at a level of detail such that

1) an experienced operator who is not familiar with a particular process unit could run the unit

with minimal supervision or help from other operators, or 2) the least experienced operator

released for unsupervised work could run the unit. Operating procedures should be readily

available for rapid reference[59].

DOE contractors should develop their own "systems" for confirming that the operating

procedures are current and accurate. Contractors must certify annually that procedures for

operation of covered processes are current and accurate [Q60].

Minimum Implementation Criteria

Operating procedures must be developed to cover all phases of process operations, including the

following [Q61].

Initial startup [Q62].

Normal operation and/or partial operation.

Temporary operation.

Emergency operations/shutdown.

Normal shutdown.

Start-up following a turnaround or after an emergency shutdown.