Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

age of the process, the number of potentially exposed employees, and the operating history.

Other appropriate factors may also be considered, such as normal delays to allow for capital

improvements to be made. Documentation should demonstrate the underlying rationale for the

prioritization.

56.

How does the percentage requirement for completion of PrHAs apply when a site has

only one or two covered processes?

Normally, if only one covered process is present, the PrHA for that process must have been

completed in its entirety as soon as possible but no later than May 26, 1994. If there are only

two covered processes, then a PrHA on the higher priority process must have been completed

not later than May 26, 1994 and the PrHA on the second not later than May 26, 1995.

What does it mean to revalidate a PrHA ?

57.

Because the PSM Rule is primarily a performance-based regulation, it includes no prescriptive

PrHA revalidation criteria. DOE contractors should determine appropriate methods for

updating/revalidating PrHAs based on the specific conditions associated with the covered

processes. Updates/revalidations must be completed by teams that meet the requirements of

the PrHA provision. Further, contractors should evaluate whether changes or incidents that

occurred since the last PrHA caused new hazards or revealed previously unrecognized ones. If

the design, operating practices, and other important circumstances associated with a covered

process have not changed since the last PrHA, a PrHA team may be able to invest minimal

effort in updating/revalidating the PrHA.

58.

Can we use PrHAs that were performed before May 26, 1992, to satisfy our initial PrHA

obligations for the processes analyzed?

PrHAs performed after May 26, 1987, may be used to satisfy the initial PrHA requirement for

covered processes as long as these PrHAs meet the other requirements of the PrHA provision.

DOE contractors must upgrade PrHAs that are deficient in order to satisfy the Rule.