Questions cont'd - doe-hdbk-1101-20040050

DOE-HDBK-1101-2004

consistent way. DOE contractors must document their prioritization of processes for

PrHA.

55.

What rationale must DOE contractors use to determine the priority for conducting

PrHAs? Should the rationale include age, history, and extent of employee exposure?

The appropriate priority for conducting PrHAs must be determined using all of the

criteria identified in this paragraph, i.e., the extent of the process hazards (catastrophic

potential), the age of the process, the number of potentially exposed employees, and the

operating history. Other appropriate factors may also be considered, such as normal

delays to allow for capital improvements to be made. Documentation should demonstrate

the underlying rationale for the prioritization.

56.

What is the time requirement for completion of PrHAs for newly covered

processes?

All initial process hazard analyses must be completed prior to process startup.

57.

What does it mean to revalidate a PrHA ?

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

prescriptive PrHA revalidation criteria. DOE contractors should determine appropriate

methods for updating/revalidating PrHAs based on the specific conditions associated

with the covered processes. Updates/revalidations must be completed by teams that meet

the requirements of the PrHA provision. Further, contractors should evaluate whether

changes or incidents that occurred since the last PrHA caused new hazards or revealed

previously unrecognized ones. If the design, operating practices, and other important

circumstances associated with a covered process have not changed since the last PrHA, a

PrHA team may be able to invest minimal effort in updating/revalidating the PrHA.

58.

How often are PrHAs performed to satisfy PrHA obligations for the processes

analyzed?

The PrHA elements must be updated and revalidated at least every five (5) years.