Step-by-Step Procedure cont'd

DOE-HDBK-1100-2004

review session is generally sufficient for this purpose. However, the more demanding PrHA

methods, such as fault tree analysis (FTA), require more training and/or a greater depth of

experience than less-rigorous methods, such as what-if and checklist analyses.

TASK G: SCHEDULE THE PrHAs.

To assure full participation by all team members, the team

leader should set up a meeting schedule that is realistic but as condensed as possible to provide a

concentrated, focused analysis.

A typical schedule is 1 to 3 days per week, with the team meeting 4 to 6 hours per day, until the

analysis is completed. The involvement of remote site personnel and/or consultants may

necessitate an even more ambitious schedule. However, the efficiency of the team tends to

decline if there are more than three, 6-hour meetings per week.

The team leader must devote additional time outside of team meetings for meeting preparation

and documentation. Preparation, such as assembling pertinent documents and deciding how

each review is approached, may take 8 to 12 hours per P&ID. Documentation typically takes

another 8 hours per P&ID.

TASK H: CONDUCT THE PrHA.

PrHAs are conducted after all up-to-date process safety

information is assembled and the team members are appropriately trained. The team should

walkdown the process and facility immediately prior to the analysis, to have the process fresh in

mind and to get a sense of the scale and orientation of the process, the surrounding facilities, and

the location of operating and co-located personnel.

A description of PrHA methods is given in Section 4 of this document. Keys to successful

PrHAs are full preparation, punctuality, focused discussions, careful evaluation of each scenario

for risk to onsite and offsite persons, and documentation of the analysis as soon as possible after

each team meeting.

TASK I: REPORT THE ANALYSIS RESULTS.

The PrHA report documents the scope, approach,

identified hazards, analyzed scenarios, and action items resulting from the PrHAs. The report

should receive close scrutiny, both for compliance with the PSM Rule and for explanations of

each action item. Guidance for reporting the PrHA results are given in Section 5.1.

TASK J: APPROVE THE REPORT AND ACTION ITEMS.

The PrHA team should present its findings

to operating management when the draft report is complete. Operating management may wish

to ask questions about the analysis or have a debriefing meeting on ways to improve the PSM

program. The team should then finalize the report. The approval of the final PrHA report by

operating management is a commitment by management to implement all action items.

Section 5.2 addresses the PrHA review process.

TASK K: ADDRESS THE ACTION ITEMS.

All action items must be addressed by operating

management, and their resolutions must be documented. Corrective actions and safety

improvements approved by management must be fully implemented in a timely manner.

Timeliness can be assured by assigning responsibilities and completion dates to all action items