Questions cont'd - hdbk11010090

DOE-HDBK-1101-96

76.

Must written maintenance procedures be specific to each vessel, type of vessel, or group

of equipment types listed?

Maintenance procedures need to be specific to the type of vessel or equipment. Identical or

very similar vessels, and items of equipment in similar service, need not have individualized

maintenance procedures. Each procedure must clearly identify the equipment to which it

applies.

What are process equipment-type controls? Are all controls and interlocks included in

77.

this type, or only the most critical ones?

Process equipment controls are controls, alarms, and interlocks that play a role in preventing or

mitigating the effects of potential catastrophic releases of HHCs to the workplace. Contractors

should consider the importance of each control, alarm, and interlock in a covered process, as

well as the results of PrHAs, in selecting the appropriate maintenance and inspection

procedures and schedules. All process control equipment is covered. Decisions affect the

frequency and nature of the inspection, test, and preventive maintenance procedures.

78.

Why are some types of process equipment (e.g., compressors, turbines, heat exchangers,

furnaces, scrubbers) left out of the list of items covered under the PSM Rule?

The PSM Rule does not exclude any equipment within a covered process that is critical to

preventing or mitigating catastrophic releases of HHCs. The equipment listed above could be

included in a generic class called "piping systems and components, pressure vessels and stor-

age tanks." Contractors should develop lists of such equipment in their facilities and assess the

safety criticality of each item. The assessment should be used to ensure that maintenance and

inspection practices are appropriate in frequency and comprehensiveness.

79.

Must DOE contractors train subcontract maintenance workers on their maintenance

procedures?

No. Procedures pertinent to subcontractor work must be provided to the maintenance

subcontractor, who is then responsible for training its own workers. However, DOE

contractors are obligated to verify that training has been performed and that subcontractor

workers follow established safe work practices, some of which may be specified in the written

maintenance procedures for covered processes. Some contractors may determine that it is

more efficient for them to train their maintenance subcontractors on unique process equipment

maintenance procedures. In these cases, the training responsibilities of the two parties should

be clearly defined and understood.

80.

Can we grandfather training requirements for existing maintenance employees? Is

refresher training required for maintenance workers?

Initial and refresher training; documentation requirements; and grandfather provisions for

training of employees operating a process have been extended to workers responsible for

maintaining the process, except that the content of the training differs.