Table 1.1 Overview of PSM Elements (Continued)

DOE-HDBK-1101-2004

Table 1.1 Overview of PSM Elements (Continued)

Incident Investigation

Using a written procedure, provide a team investigation of

any incident which results in, or could reasonably result in,

a catastrophic release of a highly hazardous chemical. Each

investigation must be documented in a written report and

findings and recommendations resolved in a timely manner.

Emergency Planning and Response Establish and implement an emergency action plan for the

entire plant that complies with 29 CFR 1910.38(a) and that

also addresses small releases.

Compliance Audit

Ensure that the PSM program is operating in an integrated

and effective manner in compliance with PSM

requirements.

Trade Secrets

Ensure all information is available to support the PSM

Rule. When necessary, confidentiality or nondisclosure

agreements may be used.

The new pressure relief system must be inspected and tested (Mechanical Integrity) and all

factors for safe operation must be reviewed (Pre-startup Safety Review [PSR]) before that

portion of the process is brought back on line. The piping and instrumentation diagrams (P&IDs)

and other engineering drawings must be revised to show the as-modified configuration of the

system (PSI). The rationale and information about the changes must be available for review by

employees and their representatives (Employee Involvement). Using this information, the PrHA

is updated to account for potential hazards associated with the new equipment. Also, inspection

and maintenance procedures and training must be updated (Mechanical Integrity, Operating

Procedures, Training).

The PSM Rule is a performance-based rule; it does not prescribe how each element is to be

implemented. Therefore, this Handbook has been developed to suggest an approach to

effectively implement the elements of this Rule within DOE. Relevant excerpts of the Rule are

provided with the discussion of each element, and the complete text is provided in Appendix B.

In addition, the discussion of each element concludes with questions and answers taken from

OSHA's interpretation of the Rule in response to industry and labor inquiries. Appendix C

compares the elements of the PSM Rule with the provisions of EPA's Risk Management

Program.

Note that the function of PSM differs from that of DOE Safety Analysis Reports (SARs). Hazard

analyses are conducted during the SAR process to identify potential accident scenarios whose

risks are assessed to determine whether designs, controls, and limits are sufficient to ensure that

a DOE facility can be operated safely in a manner that adequately protects workers, the public,

and the environment. Unmitigated releases are compared against the evaluation guidelines to

determine whether they challenge those guidelines. PrHAs are conducted to identify all process

hazards and to evaluate the adequacy of control measures for each hazard. As discussed in