Minimum Implementation Criteria cont'd

DOE-HDBK-1101-96

Procedures must include operating limits and the steps required to correct or avoid deviation from

these limits. Operators must be able to recognize a deviation that affects safety, and know what to

do to maintain control. They must know the consequences of deviations, what actions to take, and

how to use the appropriate safety equipment.

Operating procedures must address safety and health considerations [Q63]. They must be reviewed

and updated regularly to ensure changes in procedures have been incorporated. In addition, the

procedures must be reviewed and updated whenever a change is made to the process, the equipment,

or the chemicals that are used.

DOE contractors must develop and implement safe work practices for controlling hazards during

operations such as lockout/tagout; confined space entry; opening process equipment or piping; and

entrance into a facility by maintenance personnel, subcontractors, laboratory workers, or other

support personnel. Safe work practices apply equally to DOE contractors and their subcontractors.

Procedures must be communicated properly to the personnel who need to use them. The users of the

procedures must be represented during the development of procedures to ensure the procedures

reflect actual practice and are easily understood. After procedures are finalized, they form the

foundation of plant-specific training programs.

At least one control room copy of all operating procedures should be available at all times. In

addition, DOE contractors must provide the ability to generate new copies if the originals are

damaged or lost.

Questions

59.

Must all of the information required under this element be kept in written form? Must it

be kept in a single document? Can it be stored electronically?

There is no specific requirement regarding a storage location for operating procedures or for

the storage medium used. Procedures can be placed in separate documents, kept at different

locations, and stored on any medium as long as accessibility requirements are met. Keeping

hard copies of written operating procedures in the control room is a good way of providing

accessibility to procedures. Contractors who use computers to store this information should

consider in advance what they would do if the computers are unavailable (e.g., during power or

network failure).

60.

What documentation is required for annual certification of operating procedures? Must

individual procedures be signed-off, or can a facility manager certify an entire operating

manual?

The PSM Rule does not require DOE contractors to use any specific wording to document the

annual certification of operating procedures. Contractors should develop their own

certification language, which should confirm that the operating procedures are current and

accurate. Contractors may choose to certify individual procedures or sets of procedures.