Documentation Requirements

DOE-HDBK-1101-96

DOE O 440.1, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND

CONTRACTOR EMPLOYEES, describes general hazard identification and analysis requirements

for occupational safety and health.

Emergency Planning DOE O 151.1, EMERGENCY MANAGEMENT SYSTEM, requires hazard

identification as the basis for emergency planning. PrHAs have direct application for identifying

chemical process hazards in support of emergency planning as required by DOE O 151.1. They

should be used to support the emergency planning element in the PSM Rule in conjunction with

consequence modeling. PrHAs, SARs, and emergency planning hazard analyses should be

combined to satisfy all program requirements whenever possible.

MOC If the PrHA identifies an issue that leads to a change in procedures, drawings, or design, the

change must be submitted through the facility's MOC systems. If the PrHA identifies an issue that

falls outside the safety envelope for a facility, that issue should be treated as a potential unreviewed

safety question as described in DOE 5480.21, UNREVIEWED SAFETY QUESTIONS.

Documentation Requirements

Written PrHAs, updates and revalidations, and documentation of resolutions to recommendations

must be kept for the life of a process and reviewed every five years. The PrHA may be a stand-alone

document or an attachment used in conjunction with facility safety documentation. A PrHA report

should identify the PrHA team members, the processes analyzed, the PrHA method used, and the

manner in which required PrHA issues were addressed. Other documentation to support the review

depends on the method selected, the covered process, and the particular needs of the facility [Q53].

Minimum Implementation Criteria

This section provides a summary of the minimum implementation criteria for the PrHA element.

DOE-HDBK-1100-96, Chemical Process Hazards Analysis, addresses the PrHA element of the

PSM Rule in detail.

Schedule PrHAs must be completed by risk-priority, based on a relative ranking of the risks of the

covered processes [Q54]. This ranking must consider the extent of the process hazards, the number

of potentially affected employees, the age of the process, and the operating history of the process.

The basis for this ranking must be documented [Q55]. DOE contractors with few processes or

simple processes should complete required PrHAs as soon as possible. The PSM Rule established a

schedule for completion of PrHAs: 25% by May 26, 1994, and 25% additional each succeeding

year, with all PrHAs completed by May 26, 1997 [Q56]. Because PrHAs must be "conducted as

soon as possible" but no later that this established schedule, DOE contractors should be prepared to

demonstrate that PrHAs could not be completed earlier than the percentage completion dates.

PrHAs must be reviewed and updated at least every 5 years and retained for the life of the process

[Q57,Q59]. PrHAs completed after May 26, 1987, which met the requirements of the PSM Rule,

were accepted as initial analyses, with review and update scedule based on their completion dates

[Q57].

Team PrHAs must be performed by a team having the following mandatory qualifications.

At least one individual with expertise in engineering and process operations.