Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

tween PrHA updates. Although there are no requirements to consider incidents that occurred outside

a facility, DOE contractors should review and consider relevant incidents that have occurred

elsewhere in their company, in the DOE complex, or in industry [Q50].

Determining the impacts of human factors requires considering the degree to which process safety

depends on human performance; whether workers can reasonably be expected to perform the tasks

they are assigned; and whether procedures and training adequately guide and prepare workers to

perform tasks correctly. The human factors assessment in a PrHA could include listing potential

human-error causes of accidents; examining the location of and access to critical safety instruments,

alarms, and equipment; or reviewing critical procedures used by operators and maintenance

personnel. For critical operations, it may be necessary to perform task hazard analyses to analyze

the operator/machine interface in process control rooms or other work locations to adequately

evaluate human factor impacts [Q52].

Addressing facility siting in a PrHA means considering the physical location of covered processes

within the plant property. A PrHA team should consider the proximity of the covered process to

workers and egress routes when evaluating the potential safety and health impacts of possible HHC

releases. The team must also consider the impact of vehicle traffic and adjacent operations on the

safety of the process. Possible facility siting issues include the location of vessels containing HHCs

and their proximity to other equipment, control rooms, maintenance shops, and administration

buildings [Q51].

Resolution of Recommendations Process hazard analysis is not an end in itself. It is a method to

identify areas of excessive risk. Therefore, a tracking system must be in place to ensure that the

findings and recommendations of the PrHA team are resolved in a timely manner, that actions taken

are documented, and that all affected operating and maintenance workers are made aware of these

actions. This system must ensure that:

findings and recommendations are addressed promptly

recommendations are resolved and documented

actions are completed as soon as possible

a schedule for all resolutions is established and followed

actions are communicated to employees affected by any changes.

Resolution of recommendations should be accomplished through a MOC system. In any case,

contractors should develop a schedule for completion of corrective actions and document the basis

for the amount of time needed [Q52].

The PrHA team's findings and recommendations must be addressed and resolved. However, DOE

contractors may reject a recommendation where it can be documented that one of the following

conditions is true.

The recommendation is based on factual errors.

The recommendation is not necessary to protect health and safety.

An alternative measure can provide a sufficient level of protection.

The recommendation is infeasible.