Questions cont'd - doe-hdbk-1101-20040049

DOE-HDBK-1101-2004

team should consider how close a covered process is to workers or high traffic areas

when evaluating the potential safety and health impacts of possible releases of HHCs.

Possible facility siting issues include the location of vessels containing HHCs and their

proximity to other equipment, control rooms, maintenance shops, and administration

buildings.

Human factors is a broad classification of issues and techniques dealing with the

functional relationship between human operators and engineered systems. In a PrHA,

human factors 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.

DOE Contractors should examine the specific needs of each covered process to

determine an appropriate way to address facility siting, human factors, and other issues in

a PrHA. These issues need not be addressed at the same level of detail for all covered

processes.

52.

The PSM Rule requires that employers promptly address the problems identified in

the PrHA in a timely manner, and complete actions as soon as possible. What time

frame is intended here?

As soon as possible means that DOE contractors must proceed with all due speed,

considering the complexity of the recommendation and the difficulty of implementation.

OSHA expects employers to resolve PrHA team recommendations promptly; normally

within weeks to a few months. DOE contractors should develop a schedule for

completion of any corrective actions expected to require more than three months to

implement and to document the basis for the extended time needed.

53.

What minimum documentation is required in a PrHA report?

Because the PSM Rule is primarily a performance-based regulation, no prescriptive

documentation requirements have been established for PrHAs. Contractors should

include sufficient information to show that the required issues in paragraph (e)(3) of the

Rule have been addressed. For example, the report should identify the PrHA team

members, the process analyzed, the selected PrHA method used, the manner in which the

required PrHA issues were addressed, and the recommendations from the study. Other

documentation to support the review depends on the method selected, the process

analyzed, and the particular needs of the facility.

54.

Can a company prioritize the PrHAs to be performed on a company-wide basis

instead of a site-specific basis? Can a large processing complex be divided into

several logical systems for the purpose of applying the phase-in provisions for initial

PrHAs?

PrHAs must be prioritized on a site-by-site basis. When PrHAs are performed on similar

processes, DOE contractors may order these analyses to make the best use of their

experience. A large, processing complex consisting of several discrete systems (e.g.,

feed, reaction, purification, storage) or containing several different HHCs may be divided

into logical separate processes as long as this division is performed in a technically