Program Leadership and Implementation

DOE-HDBK-1101-96

Risk-Based Priorities

For DOE sites with several processes covered under the PSM Rule, completion of PSI and PrHAs

must be prioritized based on risk factors associated with the processes. Risk factors suggested by the

PSM Rule include the extent of the process hazards, the number of potentially affected employees,

the age of the process, and past performance of the process. Other factors might include the

complexity of the process or ratios of quantities of HHCs to their respective TQs. The prioritized list

of processes and the criteria used to rank the processes must be documented as part of the PSM

program records.

Resources and Schedule

The implementation of the PSM Rule at sites with extensive chemical processes may require

additional resources to develop an integrated PSM program. Many DOE sites may have already

completed much of the work necessary to comply with the PSM Rule. In fact, all elements of the

PSM Rule should already be in place, except for PSI packages and the conduct of PrHAs. Accord-

ing to the Rule, these two elements may be phased in over a 5-year period. PSM implementation

schedules must attempt to comply with the schedule established by the Rule. Additional sources of

information regarding PSM program implementation are provided in Appendix D.

3.3 Program Leadership and Implementation

Management Commitment

Studies of the most effective safety programs show a high degree of management commitment.

Thus, consistent emphasis on PSM and management attention to PSM programs are necessary for

these programs to effectively prevent releases of HHCs.

Responsibilities and PSM Integration

Because responsibilities for PSM elements are scattered throughout DOE contractor organizations,

clear assignment of responsibilities within PSM programs is essential. However, because a PSM

program requires a single point of leadership, each affected site should identify a PSM Coordinator

to be responsible for integrating all PSM elements. The PSM Coordinator might chair a site PSM

committee composed of representatives from all supporting organizations. The PSM Coordinator

might be the manager of a covered process, or the PSM subject-matter expert in the safety organiza-

tion.

One of the most critical challenges in implementing an effective PSM program is integrating or

forging 14 diverse management elements into a single management system focused on process

safety. Many aspects of the PSM program exist within DOE. However, these elements often

operate independently because they are performed by different departments within contractor

organizations. A PSM program cannot succeed without good communication and coordination

among elements. Careful implementation of the MOC element can provide critical linkages

necessary for integration.

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