Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

Questions

47.

What characteristics does an "appropriate equivalent methodology" need to be consid-

ered acceptable for performing a PrHA?

Any technique or combination of techniques used to perform a PrHA must address the issues

specified in this provision (e.g., the extent of hazards, the qualitative description of range of

consequences). Moreover, the methods should generate the types of results and documentation

required by the Rule (e.g., a list of recommendations). Beyond these criteria, a PrHA method

should help ensure a thorough evaluation of potential safety and health impacts from process

equipment failures and human errors.

48.

What training/experience is necessary for a member of the PrHA team to be considered

knowledgeable in the selected PrHA methodology? What documentation is required?

Knowledge of the PrHA method selected for use for a particular process is required for only

one member of the PrHA team. There are no specific requirements for PrHA qualifications or

for documenting the qualifications of PrHA team members. Detailed hands-on classroom

training on PrHA methods is an appropriate way for team members to gain necessary knowl-

edge of a specific PrHA method. Previously demonstrated experience in the use of the tech-

nique may also be accepted as sufficient "qualification" for PrHA team leaders. Contractors

may elect to compile a list of PrHA-qualified individuals at a facility along with their PrHA

experience.

49.

If batch processes involve hundreds of recipes and chemicals, must a separate PrHA be

performed on each recipe, or can these PrHAs be done generically?

PrHAs for batch processes that use a variety of chemicals and recipes can be performed on a

generic basis as long as the chemicals and recipes represent the full range of possible

processing circumstances, including worst case situations. The technical basis for this worst-

case selection of circumstances should be documented.

50.

Is identification of previous incidents restricted to the specific facility or must DOE

contractors conduct an industry-wide search for incident information?

The PSM Rule requires DOE contractors to address in the PrHA previous incidents at their

facilities that had a reasonable potential for catastrophic effects in the workplace. Although

there are no requirements to consider incidents that occurred outside a facility, DOE

contractors should review relevant incidents that have occurred elsewhere in their company, in

the DOE complex, or in industry.

51.

How should facility siting and human factors be addressed in a PrHA?

Facility siting means the location of covered processes within the plant property. A PrHA

team should consider how close a covered process is to workers or high traffic areas when

evaluating the potential safety and health impacts of possible releases of HHCs. Possible

facility siting issues include the location of vessels containing HHCs and their proximity to

other equipment, control rooms, maintenance shops, and administration buildings.