Documentation Requirements cont'd

DOE-HDBK-1101-96

PSI should contain a description of the function and design basis for all ventilation systems

whose purpose is to maintain a healthy environment, particularly when these ventilation sys-

tems are used to maintain a safe haven in the event of a catastrophic release of a HHC.

PSI should contain a functional description of the safety systems in a covered process. Safety

systems are systems designed to control and maintain a process within safe design parameters.

Examples of safety systems are interlocks, scrubbers, flares, and detection systems for releases

of toxic or flammable chemicals. Workers should know what protective features exist and how

to use these safety systems in an emergency.

Chemical hazard information should contain information on the incompatibility of HHCs with

materials that are known to exist in the workplace. Employees routinely working with materi-

als commonly found around a covered process should be familiar with the potential safety and

health impacts from inadvertently combining these materials with the HHC.

44.

Do we have to keep hard copies of all of the PSI or can we use electronic media?

There is no specific storage requirement for PSI or any other documentation created under the

PSM Rule. Any medium may be used as long as the accessibility requirements are met. How-

ever, DOE contractors who use electronic storage media should consider in advance what they

will do when computers used to access this information are unavailable (e.g., during power

failures).

45.

How long must DOE contractors maintain process safety information?

To demonstrate compliance and to meet the intent of the PSM Rule, PSI must be kept for the

lifetime of a process and updated whenever changes other than replacement in kind are made.

46.

How can a PrHA be used to demonstrate that equipment is designed safely?

The PrHA can be used to perform a sensitivity analysis to evaluate the impacts of using

equipment or facilities which have not been designed to current codes and standards.