Establishing A System for Resolving Action Items and Implementing Corrective Actions

D0E-HDBK-1100-2004

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6.0 ESTABLISHING A SYSTEM FOR RESOLVING ACTION ITEMS

AND IMPLEMENTING CORRECTIVE ACTIONS

Activities documenting and tracking implementation of corrective actions or safety

improvements are not part of a PrHA report. However, the PSM Rule requires a documented,

integrated system for managing and monitoring action items. This system must assure that

action items and recommendations are addressed and documented in a timely manner.

Implementation schedules for corrective actions or safety improvements must be tracked.

Finally, the system must assure that all affected operating and maintenance personnel and other

affected employees are notified of planned actions.

In addition to these requirements, if a PrHA is conducted to satisfy safety analysis requirements

of 10 CFR 830 Subpart B NUCLEAR SAFETY MANAGEMENT, SAFETY BASIS

REQUIREMENTS, the resolution of action items must be documented to obtain approval of the

safety analysis and the startup of the facility. In this case, the contractor may be required to

satisfy specific safety criteria before an action item is considered resolved.

6.1

Process Hazard Analysis Action Items and Recommendations

The critical result of a PrHA is the list of action items developed by the PrHA team. Action

items are written any time the team thinks that additional effort is warranted to review further a

specific scenario, to eliminate a hazard, or to reduce risks. Usually, action items do not

recommend specific corrective actions. They are meant to alert management to potential

problems. Sometimes, action items may suggest alternatives to be considered. However, if a

problem is simple, if a PrHA team is quite experienced, or if there is only one obvious solution,

an action item may be written to recommend a specific corrective action.

The action items from a PrHA are presented to management for review and evaluation, and for

determination of what, if any, corrective actions should be taken to eliminate hazards or to

reduce risks through preventative, protective, or mitigative measures. Because many action

items may be generated during a PrHA, the team may choose to rank the action items according

to the probability of occurrence of their corresponding accident scenarios or the severity of their

consequences or both. If the PrHA team is quite experienced, it may also choose to rank the

action items based on the anticipated time and resources required to implement changes.

6.2

Criteria for Corrective Actions and Safety Improvements

Management can use a variety of criteria to select and prioritize corrective actions and safety

improvements. They include costs, other competing priorities, implementation schedules, the

effectiveness of risk reduction, and technical feasibility. These criteria, as well as management

decisions about corrective actions, must be documented. If after evaluating an action item,

management chooses to take no further action, that decision must also be documented. In

addition to requiring documentation of management decisions, the PSM Rule requires a system

to track implementation of corrective actions to be made.