Step-by-Step Procedure cont'd

DOE-HDBK-1100-2004

TASK C: SELECT A PrHA METHOD FOR EACH PROCESS.

Paragraph (e)(2) of the PSM Rule

implies that it is the responsibility of the DOE contractor to select the review method, not the

choice of the team conducting the review. In some cases, a combination of methods may be

used.

TASK D: ESTIMATE THE MANPOWER REQUIRED AND DEVELOP A STAFFING PLAN.

The

manpower required to conduct a PrHA depends on many factors, including the review method

selected, the training and experience of the review team, the extent and complexity of the

process, its instrumentation and controls, and whether the process is a procedure-oriented

operation (such as a batch reaction) or a continuous operation (such as petroleum refining). In

addition, reviews and updates of existing PrHAs tend to be less time consuming than initial

analyses. Guidance for estimating PrHA time requirements is given for each review method in

Sections 4.1 to 4.6.

Based on the analysis methods selected in Task C, the status of existing PrHAs, and the time

requirements for the methods reviewed in Sections 4.1 to 4.6, the manpower requirements for

PrHAs, and reviews and updates, can be estimated. Comparing these requirements with

available personnel indicates where additional staffing may be needed, either on a temporary or

longer-term basis.

TASK E: SELECT A PROCESS TO BE ANALYZED.

This selection should be straightforward: the

process to be analyzed should be the process highest on the prioritized list (Task B). If there are

exceptions, justifications should be carefully documented. For example, if the highest process

on a prioritized list has some significant process changes planned, it may be reasonable to

analyze the process being modified along with its proposed changes.

TASK F: ASSEMBLE THE PrHA TEAM AND TRAIN THE TEAM MEMBERS.

Regardless of the method

selected, the PSM Rule requires all PrHAs to be performed by a team. This team is an ad hoc

committee, formed solely to conduct a PrHA for an assigned process. It is disbanded after the analysis,

including documentation, has been completed.

The review team must have expertise in engineering and process operations, and at least one

team member must have experience and knowledge specific to the process being evaluated. If

the process is a new design, the experience requirement may be satisfied by bringing in a person

from a sister plant or from a similar or precursor process. In addition, at least one member of

the team must be knowledgeable in the hazard analysis methodology being used (see note at the

end of Section 1.0).

All team members should be familiar with PrHA objectives, the PrHA method to be used, and

their roles in performing the PrHA. A 1- or 2-hour overview at the beginning of the first team