Documentation Requirements - doe-hdbk-1101-20040039

DOE-HDBK-1101-2004

Most DOE contractors have hazard communication programs that use information from

Materials Safety Data Sheets (MSDSs) to comply with 29 CFR 1910.1200. Information about

the hazards posed by most process chemicals may also be obtained from MSDSs. Additional

information may be required to describe process chemistry conditions that can lead to

overpressures or runaway reactions. DOE information requirements regarding hazard

identification are included in DOE O 151.1B, COMPREHENSIVE EMERGENCY

MANAGEMENT SYSTEM, DOE O 420.1A FACILITY SAFETY, DOE O 430.1B, REAL

PROPERTY ASSET MANAGEMENT, and DOE O 440.1A, WORKER PROTECTION

MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES.

Some DOE facilities, especially nuclear facilities, have design information for systems,

structures, and components to support Safety Analysis Reports (SARs) and ongoing engineering

improvements to systems. Systems for maintaining as-built drawings of processes, together with

their original design basis and history of modifications, may be available for these facilities.

However, documentation of the design basis for older DOE facilities and nonnuclear facilities is

often weak.

New DOE facilities are required under DOE O 430.1B to meet certain facility safety

requirements. SARs for existing facilities require that the facility design be evaluated for

conformance with these requirements. Statements in the design information and/or the SAR

regarding compliance with these safety design requirements provide documentation that facilities

and equipment are designed in accordance with recognized and generally accepted good

engineering practices. DOE information requirements associated with the technology and

equipment of a nuclear process are found in 10 CFR 830 Subpart B, NUCLEAR SAFETY

MANAGEMENT, SAFETY BASIS REQUIREMENTS.

Documentation Requirements

The PSI element is a documentation requirement. It specifies the minimum written PSI package

needed to support a PSM program. It should be updated as part of the MOC element of the PSM

Rule because the safety of processes depends on workers having access to accurate process

safety information. PSI used to support the development of facility safety documentation or

PrHAs should be referenced. PSI need not be located in one document or in one place [Q42].

Electronic storage media may be used so long as a backup version is available at all times [Q44].

PSI should be part of the facility configuration information and should be maintained for the life

of a process through a configuration management system [Q45].

Complete PSI packages are essential for conducting PrHAs. Initial PSI is required to establish

risk-based priorities for completion of PrHAs.

Minimum Implementation Criteria

Adequate information must be available to support preparation of PrHAs, operating procedures,

training materials, and emergency plans. The PrHA team can generate information on process

technology when complete information does not exist. In addition, documentation must be

available to confirm that process equipment complies with recognized and generally accepted