Table 1.1 Overview of PSM Elements (Continued)

DOE-HDBK-1101-96

Table 1.1 Overview of PSM Elements (Continued)

Incident Investigation

Using a written procedure, provide a team investigation of

any incident which results in, or could reasonably result in,

a catastrophic release of a highly hazardous chemical.

Each investigation must be documented in a written report

and findings and recommendations resolved in a timely

manner.

Emergency Planning and Response

Establish and implement an emergency action plan for the

entire plant that is in compliance with 29 CFR 1910.38(a)

and that also addresses small releases.

Compliance Audits

Ensure that the PSM program is operating in an integrated

and effective manner in compliance with PSM require-

ments.

Trade Secrets

Ensure all information is available to support the PSM

Rule. When necessary, confidentiality or nondisclosure

agreements may be used.

(Mechanical Integrity) and all factors for safe operation must be reviewed (Pre-startup Safety

Review [PSR]) before that portion of the process is brought back on line. The piping and

instrumentation diagrams (P&IDs) and other engineering drawings must be revised to show the as-

modified configuration of the system (PSI). The rationale and information about the changes must

be available for review by employees and their representatives (Employee Involvement). Using this

information, the PrHA is updated to account for potential hazards associated with the new

equipment. Also, inspection and maintenance procedures and training must be updated (Mechanical

Integrity, Operating Procedures, Training).

The PSM Rule is a performance-based rule; it does not prescribe how each element is to be

implemented. Therefore, this Handbook has been developed to suggest an approach to effectively

implement the elements of this Rule within DOE. Relevant excerpts of the Rule are provided with

the discussion of each element, and the complete text is provided in Appendix B. In addition, the

discussion of each element concludes with questions and answers taken from OSHA's interpretation

of the Rule in response to industry and labor inquiries. Appendix C compares the elements of the

PSM Rule with the provisions of EPA's Risk Management Program.

Note that the function of PSM differs from that of DOE Safety Analysis Reports (SARs). Hazard

analyses are conducted during the SAR process to identify potential accident scenarios whose risks

are assessed to determine whether designs, controls, and limits are sufficient to ensure that

consequences do not exceed evaluation guidelines. PrHAs are conducted to identify all process

hazards and to evaluate the adequacy of control measures for each hazard. As discussed in Section

2.3, PrHAs may be used to support development of SARs. SARs may incorporate information on