Minimum Implementation Criteria cont'd

DOE-HDBK-1101-2004

investigation provision of this Rule, contractors are required to retain incident reports for 5

years, the time between PrHA updates. Although there are no requirements to consider incidents

that occurred outside a facility, DOE contractors should review and consider relevant incidents

that have occurred elsewhere in their company, in the DOE complex, or in industry [Q50].

Determining the impacts of human factors requires considering the degree to which process

safety depends on human performance; whether workers can reasonably be expected to perform

the tasks they are assigned; and whether procedures and training adequately guide and prepare

workers to perform tasks correctly. The human factors assessment in a PrHA 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. For critical operations, it may be necessary to perform task hazard

analyses to analyze the operator/machine interface in process control rooms or other work

locations to adequately evaluate human factor impacts [Q52].

Addressing facility sitting in a PrHA means considering the physical location of covered

processes within the plant property. A PrHA team should consider the proximity of the covered

process to workers and egress routes when evaluating the potential safety and health impacts of

possible HHC releases. The team must also consider the impact of vehicle traffic and adjacent

operations on the safety of the process. Possible facility sitting issues include the location of

vessels containing HHCs and their proximity to other equipment, control rooms, maintenance

shops, and administration buildings [Q51].

Resolution of Recommendations Process hazard analysis is not an end in itself. It is a method to

identify areas of excessive risk. Therefore, a tracking system must be in place to ensure that the

findings and recommendations of the PrHA team are resolved in a timely manner, that actions

taken are documented, and that all affected operating and maintenance workers are made aware

of these actions. This system must ensure that:

findings and recommendations are addressed promptly

recommendations are resolved and documented

actions are completed as soon as possible

a schedule for all resolutions is established and followed

actions are communicated to employees affected by any changes.

Resolution of recommendations should be accomplished through a MOC system. In any case,

contractors should develop a schedule for completion of corrective actions and document the

basis for the amount of time needed [Q52].

The PrHA team's findings and recommendations must be addressed and resolved. However,

DOE contractors may reject a recommendation where it can be documented that one of the

following conditions is true.

The recommendation is based on factual errors.

The recommendation is not necessary to protect health and safety.

An alternative measure can provide a sufficient level of protection.

The recommendation is infeasible.