DOE-HDBK-1101-2004, Process Safety Management for Highly Hazardous Chemicals

NOT MEASUREMENT SENSITIVE DOE-HDBK-1101-2004 August 2004 Superseding DOE-HDBK-1101-96 February 1996 DOE HANDBOOK PROCESS SAFETY MANAGEMENT FOR HIGHLY HAZARDOUS CHEMICALS U.S. Department of Energy AREA SAFT Washington, D.C. 20585 DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited. DOE-HDBK-1101-2004 This document has been reproduced directly from the best available copy. Available to DOE and DOE contractors from the ES&H Technical Information Services, U.S. Department of Energy, (800) 473-4375, fax: (301) 903-9823. Available to the public from the U.S. Department of Commerce, Technology Administration, National Technical Information Service, Springfield, VA 22161; (703) 605-6000. ii DOE-HDBK-1101-2004 ACKNOWLEDGEMENTS The U.S. Department of Energy (DOE) wishes to thank several organizations for their support in developing this handbook. The Occupational Safety and Health Administration (OSHA) staff provided assistance. Mobil Chemical, General Electric, and Dow Chemical graciously shared their process safety management experience and program materials. JBF Associates shared sample programs and responses by an OSHA/industry panel to process safety management questions. Mr. John Piatt of Pacific Northwest National Laboratories (PNNL) managed the preparation of this standard by Battelle Memorial Institute staff at PNNL and the Battelle Columbus Division. iii DOE-HDBK-1101-2004 FOREWORD The Office of Health (EH-5) under the Assistant Secretary for Environment, Safety and Health of the U.S. Department of Energy (DOE) has published two handbooks for use by DOE contractors managing facilities and processes covered by the Occupational Safety and Health Administration (OSHA) Rule for Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119), herein referred to as the PSM Rule. The PSM Rule contains an integrated set of chemical process safety management elements designed to prevent chemical releases that can lead to catastrophic fires, explosions, or toxic exposures. The purpose of the two handbooks, "Process Safety Management for Highly Hazardous Chemicals" and "Chemical Process Hazards Analysis," is to facilitate implementation of the provisions of the PSM Rule within the DOE. This handbook provides information necessary to determine if a chemical process is covered by the PSM Rule and provides an interpretation of the 14 elements of the PSM Rule. An overview of these elements is given in Table 1.1. This handbook also describes DOE programs that may, with or without modification, satisfy the requirements of this Rule. Questions and answers, based on OSHA's responses to questions from industry and labor, are provided at the end of most sections. Applicable question numbers are referenced in the text in brackets. Sample programs are included that may be used to satisfy provisions of the PSM Rule. These sample programs are adapted from industry and are not mandatory, even though some contain directive language (e.g., will, shall, should). Appendix D lists additional sources of detailed PSM information. For specific guidance on the Process Hazards Analysis element, the reader is referred to the handbook, "Chemical Process Hazards Analysis" (DOE-HDBK-1100-2004). OSHA's performance-based Rule permits great latitude in how its requirements are implemented, so long as the objectives of each element are met. This handbook recognizes this latitude, but attempts to guide DOE contractors toward efficient and effective options, given existing DOE Orders and requirements. These handbooks describe PSM Rule implementation in terms of industry practices and do not supercede any DOE Orders or requirements.

Promulgation of the PSM Rule has heightened the awareness of chemical safety management issues within the DOE. Contractors whose chemical processes are not covered by the PSM Rule may use these handbooks as a basis for good safety management practices. Implementation of PSM programs is expected to be a dynamic process. Further information and interpretations may be issued as necessary to clarify the Rule. DOE has an OSHA interpretation phone line at 1-800-292-8061 where DOE contractors can direct questions not covered in this handbook. iv DOE-HDBK-1101-2004 TABLE OF CONTENTS ACKNOWLEDGEMENTS ........................................................................................................ i FOREWORD............................................................................................................................... iv LISTS OF FIGURES, TABLES, AND EXHIBITS.................................................................... vii ACRONYMS ............................................................................................................................. vii GLOSSARY................................................................................................................................ x REFERENCES ........................................................................................................................... xiv 1.0 INTRODUCTION ................................................................................................................ 1 1.1 Purpose ............................................................................................................................ 1 1.2 Background ..................................................................................................................... 5 1.3 Application ...................................................................................................................... 5 2.0 PROCESS SAFETY MANAGEMENT ELEMENTS.......................................................... 15 2.1 Employee Participation ................................................................................................... 16 2.2 Process Safety Information ............................................................................................. 21 2.3 Process Hazard Analysis ................................................................................................. 27 2.4 Operating Procedures ...................................................................................................... 35 2.5 Training ........................................................................................................................... 40 2.6 Subcontractor Safety ....................................................................................................... 44 2.7 Pre-Startup Safety Review .............................................................................................. 63 2.8 Mechanical Integrity ....................................................................................................... 71 2.9 Nonroutine Work Authorizations (Hot Work Permits)................................................... 76 2.10 Management of Change .................................................................................................. 79 2.11 Incident Investigation...................................................................................................... 85

2.12 Emergency Planning and Response ................................................................................ 88 2.13 Compliance Audits .......................................................................................................... 90 2.14 Trade Secrets ................................................................................................................... 113 3.0 PSM PROGRAM DEVELOPMENT.................................................................................... 115 3.1 Defining Process Safety Management Policy, Goals, and Objectives............................ 115 3.2 Process Safety Management Planning ............................................................................ 115 3.3 Program Leadership and Implementation ....................................................................... 117 v DOE-HDBK-1101-2004 APPENDICES APPENDIX A OSHA and EPA Lists of Highly Hazardous Substances and Threshold Quantities (TQ) for Accidental Release Prevention .................... A1 APPENDIX B The Process Safety Management Rule.......................................................... B1 APPENDIX C Comparison of the EPA Risk Management Program with OSHA's Process Safety Management Program..................................... C1 APPENDIX D Sources of Information.................................................................................. D1 vi DOE-HDBK-1101-2004 LIST OF FIGURES Figure 1.1 Chemical Safety Programs Related to Accident Consequence ................................. 4 Figure 1.2 Applicability of the PSM Rule................................................................................... 7 Figure 2.1 The Process Safety Management System .................................................................. 15 LIST OF TABLES Table 1.1 Overview of PSM Elements........................................................................................ 2 LIST OF EXHIBITS Exhibit 2.1 Sample Employee Participation Plan ....................................................................... 18 Exhibit 2.6.1 Sample Subcontractor Safety Program.................................................................. 48 Exhibit 2.6.2 Sample Subcontractor Safety Questionnaire ......................................................... 54 Exhibit 2.6.3 Sample Subcontractor Safety Program Evaluation and Criteria ........................... 57 Exhibit 2.7 Sample Prestartup Safety Review ............................................................................ 65 Exhibit 2.9 Sample Hot Work Permit ......................................................................................... 78 Exhibit 2.10 Sample Management of Change Form ................................................................... 83 Exhibit 2.13 Sample PSM Audit Report Form ........................................................................... 93 vii DOE-HDBK-1101-2004 ACRONYMS ANSI American National Standards Institute API American Petroleum Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials CCPS Center for Chemical Process Safety CERCLA Comprehensive Environmental Response, Compensation and Liability

Act CFR Code of Federal Regulations DOE U.S. Department of Energy DOT U.S. Department of Transportation DCS Distributed Control System EMR Experience Modification Rate EPA Environmental Protection Agency ERPG Emergency Response Planning Guideline ES&H Environment, Safety, and Health EVC Equilibrium Vapor Concentration FMEA Failure Mode and Effects Analysis FTA Fault Tree Analysis GOCO Government Owned Contractor Operated HAZCOM Hazard Communication (Standard) HAZOP Hazard and Operability Analysis HDBK Handbook Hg Mercury (Atomic Symbol) HHC Highly Hazardous Chemical IDLH Immediately Dangerous to Life or Health IEEE Institute of Electrical and Electronic Engineers ISA Instrument Society of America JHA Job Hazard Analysis JSA Job Safety Analysis LPG Liquid Petroleum Gas M&O Management and Operating MOC Management of Change MSDS Materials Safety Data Sheet NDT Nondestructive Testing NFPA National Fire Protection Association ORC Organization Resources Counselors OSHA Occupational Safety and Health Administration P&ID Piping and Instrumentation Diagram PEL Permissible Exposure Limit PrHA Process Hazard Analysis PSI Process Safety Information viii DOE-HDBK-1101-2004 PSM Process Safety Management PSR Pre-Startup Safety Review PSI Process Safety Information PSM Process Safety Management PSR Prestartup Safety Review QA Quality Assurance RCRA Resource Conservation and Recovery Act RMP Risk Management Program SAR Safety Analysis Report SASS Safety Assurance System Summary SCBA Self-Contained Breathing Apparatus SHI Substance Hazard Index SOP Standard Operating Procedure TLV Threshold Limit Value TQ Threshold Quantity TSD Treatment, Storage, and Disposal ix DOE-HDBK-1101-2004 GLOSSARY Accident, Accident Event Sequence An unplanned event or sequence of events that has an undesirable consequence. Aggregate Threshold Quantity The total amount of a particular hazardous chemical contained in vessels that are interconnected, or contained in a process and nearby unconnected vessels that may be adversely affected by an incident at that process. Atmospheric Tank A storage tank that has been designed to operate at pressures from atmospheric pressure 1.01 x 106 dynes/cm2 (14.7 psia) through 1.05 x 106 dynes/cm2 (15.2 psia). Audit (Process Safety Audit) An inspection of a plant or process unit, drawings, procedures, emergency plan, and/or management systems by an independent team. Battery Limits That portion of a chemical plant in which the actual processes are carried out, as distinguished from storage buildings, offices, and other subordinate structures. Boiling Point The initial temperature at which a liquid begins to pass into the gaseous phase at a pressure of 1.01 x 106 dynes/cm2 (14.7 psia). If an accurate boiling point is not available, see ASTM D-86-62. Catastrophic Release A major uncontrolled emission, fire, or explosion, involving one or more highly hazardous chemicals, that presents serious danger to employees in the workplace or to the public. Consult To exchange information and solicit input and participation from workers and their representatives in developing a written employee action plan and process hazard analyses; and to provide employees with access to information required under the Rule. Contractor For the purposes of this document, contractor in the PSM Rule refers to DOE subtier contractors, i.e., subcontractors of DOE contractors. x DOE-HDBK-1101-2004

Employee Under 29 CFR 1910.119, an hourly, salaried, or contract individual who works at a facility and comes in direct contact with a covered process [Q36]. Event An occurrence involving process, equipment, or human performance either internal or external to a system that causes system upset. In terms of accidents, an event is either a cause or contributing cause of a near miss or accident, or a response to the accident-initiating event. Facility The buildings, containers, or equipment that contain a chemical process. Flammable Gas A gas that at ambient temperature and pressure forms a flammable mixture with air at a concentration of 13% by volume or less, or a gas that at ambient temperature and pressure forms a range of flammable mixtures with air wider than 12% by volume, regardless of the lower limit. Flammable Liquid A liquid with a flash point below 37.8 oC (100 oF), except mixtures where such liquids account for 1% or less of the total volume. Hazard A chemical property, energy source, or physical condition that has the potential to cause illness, injury, or death to personnel, or damage to property or to the environment, without regard for the likelihood or credibility of potential accidents or the mitigation of consequences. Highly Hazardous Chemical (HHC) Toxic, reactive, flammable, or explosive substances, such as those identified in the PSM Rule. Hot Work Work involving electric or gas welding, cutting, brazing, grinding, or similar flame- or spark- producing operations capable of igniting flammable vapors or gases. Management Systems Arrangements for guiding and controlling the work of complex organizations. Near Miss An event that did not result in an accidental release of a highly hazardous chemical, but which could have, given another “failure.” Near misses, sometimes called “precursors,” include: xi DOE-HDBK-1101-2004 • the occurrence of an accident initiator where the protection functioned properly to preclude a release of a highly hazardous chemical, or • the determination that a protection system was out of service such that if an initiating event had occurred, a release of the highly hazardous chemical would have taken place. Normally Unoccupied Remote Facility A facility that is operated, maintained, or serviced by workers who visit the facility only periodically to check its operation and to perform necessary operating or maintenance tasks. No workers are regularly or permanently stationed at the facility. Such facilities are not contiguous with, and must be geographically remote from, all other buildings, processes, or persons [Q22]. Probability An expression of the likelihood that an event or event sequence will occur during an interval of time, or the likelihood of the success or failure of an event on test or on demand. By definition, probability must be expressed as a number ranging from 0 to 1. Process Any onsite [Q25] activity that involves a highly hazardous chemical, including any use, storage, manufacturing, handling, and/or movement of a highly hazardous chemical. Any interconnected group of vessels is considered a single process. Vessels with no physical interconnections located such that an accident in one vessel could spread to adjacent vessels are considered a single process. Process Change Modification of a facility, process, procedure or operation that is significant enough to alter the process safety information (see Section 2.10, Management of Change).

Process Hazards Analysis (PrHA) The application of one or more analytical methods to identify and evaluate process hazards for the purpose of determining the adequacy of or need for control measures. Process Safety Management (PSM) The application of management principles, methods, and practices to prevent and control accidental releases of process chemicals or energy. PSM Rule The Occupational Safety and Health Administration's "Rule for Process Safety Management of Highly Hazardous Chemicals," 29 CFR 1910.119. Replacement in Kind A replacement that satisfies the design specification. xii DOE-HDBK-1101-2004 Risk The quantitative or qualitative expression of possible loss that considers both the probability that a hazard will result in an adverse event and the consequences of that event. Subtier Contractor An individual or organization contracted to a DOE contractor. Threshold Quantity (TQ) The minimum amount of a toxic, reactive, or flammable chemical judged by OSHA as capable of causing a catastrophic event. The threshold quantity triggers application of the PSM Rule's requirements. Trade Secret Any confidential formula, pattern, process, device, information, or compilation of information used in a business that provides a competitive advantage. In the DOE context, trade secrets include classified information. xiii DOE-HDBK-1101-2004 REFERENCES DOE Orders, Guides, and Manuals (Manuals are not listed unless the title is different from parent Order.) DOE O 151.1B COMPREHENSIVE EMERGENCY MANAGEMENT SYSTEM DOE O 225.1A ACCIDENT INVESTIGATION DOE O 231.1A ENVIRONMENTAL, SAFETY, AND HEALTH REPORTING DOE G 231.1-1 OCCURRENCE REPORTING AND PERFORMANCE ANALYSIS GUIDE DOE G 231.1-2 OCCURRENCE REPORTING CASUAL ANALYSIS GUIDE DOE M 231.1-2 OCCURRENCE REPORTING AND PROCESSING OF OPERATIONS INFORMATION DOE O 360.1B FEDERAL EMPLOYEE TRAINING DOE O 412.1 WORK AUTHORIZATION SYSTEM DOE O 414.1A Chg 1 QUALITY ASSURANCE DOE G 414.1-1A MANAGEMENT ASSESSMENT AND INDEPENDENT ASSESSMENT GUIDE DOE G 414.1-2 QUALITY ASSURANCE MANAGEMENT SYSTEM GUIDE FOR USE WITH 10 CFR 830.120 AND DOE O 414.1A Chg 1 DOE O 420.1A FACILITY SAFETY DOE G 424.1-1 IMPLEMENTATION GUIDE FOR USE IN ADDRESSING UNREVIEWED SAFETY QUESTION REQUIREMENTS DOE O 425.1C STARTUP AND RESTART OF NUCLEAR FACILITIES DOE O 430.1B REAL PROPERTY ASSET MANAGEMENT DOE O 440.1A WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES xiv DOE-HDBK-1101-2004 DOE M 440.1-1 DOE EXPLOSIVES SAFETY MANUAL DOE O 5480.19 Chg 2 CONDUCT OF OPERATIONS REQUIREMENTS FOR DOE FACILITIES DOE O 5480.20A Chg 1 PERSONNEL SELECTION, QUALIFICATION, AND TRAINING REQUIREMENTS FOR DOE NUCLEAR FACILITIES DOE Standards and Handbooks DOE-STD-1027-92 (CH-1) Hazard Categorization and Accident Analysis Techniques for Compliance with DOE order 5480.23, Nuclear Safety Analysis Reports DOE-STD-1029-92 (CH-1) Writers’ Guide for Technical Procedures DOE-STD-1073-2003 Configuration Management DOE-HDBK-1100-2004 Chemical Process Hazards Analysis DOE-HDBK-1205-97 Guide to Good Practices for the Design, Development and Implementation of Examinations OSHA Standards 1910.38 Employee Emergency Plans and Fire Prevention Plans 1910.38 (a) Emergency Action Plan 1910.106 Flammable and combustible Liquids

1910.109 Explosives and Blasting Agents 1910.119 Process Safety Management of Highly Hazardous Chemicals 1910.120 Hazardous Waste Operations and Emergency Response 1910.252 General Requirements (Welding, Cutting, and Brazing) 1910.252 (a) Fire Prevention and Protection 1910.1200 Hazard Communication 1910.1200 (g) Material Safety Data Sheets 1910.1200 (i) Trade Secrets xv DOE-HDBK-1101-2004 Other References DOE Report, “Example Process Hazard Analysis of a Department of Energy Water Chlorination Process”, DOE/EH-0340, September 1993. See Appendix D for other sources of information on PSM topics. xvi DOE-HDBK-1101-2004 1.0 Introduction 1.1 Purpose The purpose of this document is to assist U.S. Department of Energy (DOE) contractors who work with threshold quantities of highly hazardous chemicals (HHCs), flammable liquids or gases, or explosives in successfully implementing the requirements of the Occupational Safety and Health Administration (OSHA) OSHA Rule for Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119), hereafter referred to as the PSM Rule. Successful implementation requires each contractor to study existing and required chemical process safety management (PSM) systems to determine that a comprehensive program is in place. Process safety management requires an ongoing effort to prevent catastrophic accidents involving hazardous process materials and energies. It applies management principles and analytic techniques to reduce risks to processes during the onsite manufacture, use, handling, storage, and movement of chemicals. Its focus is on hazards related to the materials and energies present in chemical process facilities. The purpose of the PSM Rule is to prevent releases of HHCs (listed in Appendix A) that have the potential to cause catastrophic fires, explosions, or toxic exposures. This objective is achieved by first building safety into a process, and then keeping the facility operating safely throughout its life cycle, by identifying process hazards and providing necessary controls over the life of the process [Q36, Q47]. PSM integrates 14 elements to manage facilities, technology, and personnel, as summarized in Table 1.1. The elements of the PSM system are employee participation, process safety information (PSI), process hazard analysis (PrHA), operating procedures, training, subcontractor safety, pre-startup safety review, mechanical integrity, nonroutine work authorizations, management of change (MOC), incident investigation, emergency management, compliance audits and trade secrets. Other DOE Orders and OSHA rules address general industrial hazards, industrial hygiene, and radiation protection. Thus, PSM is just one program in a comprehensive safety management system. Figure 1.1 shows how PSM and other OSHA chemical safety programs apply to the accident consequence continuum. The following example shows how the PSM elements are integrated in actual practice. Pilot studies indicate that higher yields can be obtained by maintaining higher temperatures in a reaction vessel. A change in operating temperature must be approved by all technical and support functions (MOC). The impact of this change is assessed though revision of the process hazard analysis (PrHA), which results in a recommendation to modify the pressure relief system. The modifications in temperature and pressure relief system mandate new steps for process operators (Operating Procedures), who require training and verification in the new procedures (Training). The modifications to the pressure relief system are made by the supplier (Contractor Safety) and require that a portion of the process be shut down for this work. The work includes a brazing operation requiring a Hot Work Permit (Nonroutine Work Authorization). Potential impacts on the process require a review of emergency response plans (Emergency Planning).

1 DOE-HDBK-1101-2004 Table 1.1 Overview of PSM Elements Employee Participation Ensure that workers and their representatives are consulted and have access to information regarding all PSM elements. Process Safety Information Maintain complete and accurate information on the process technology, process equipment, and hazardous characteristics and physical properties of all chemicals and intermediates for all covered processes. Process Hazard Analysis Identify and assess process hazards for each covered process, and take action to manage risk. Operating Procedures Provide clear written instructions for safely conducting activities at each covered process that address operating limits, safety and health considerations, and safety systems and their functions. Training Provide initial and refresher training with a means of verifying employee understanding for all employees involved in operating a covered process. Subcontractor Safety Ensure that subcontractor operations do not compromise the level of safety on or in the vicinity of a process using HHCs. Pre-Startup Safety Review Perform safety reviews for new and modified facilities prior to operation when the modification is significant enough to require a change in the process safety information. Mechanical Integrity Ensure the integrity and safe operation of process equipment through inspection, testing, preventive maintenance, and quality assurance. Nonroutine Work Authorizations Ensure that appropriate measures are taken any time nonroutine operations are performed on or near covered process areas that might initiate or promote a release. Management of Change Establish and implement written procedures to manage changes(except for replacements in kind) to process chemicals, technology, equipment, and procedures, and to facilities that affect a covered process. 2 DOE-HDBK-1101-2004 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 complies with 29 CFR 1910.38(a) and that also addresses small releases. Compliance Audit Ensure that the PSM program is operating in an integrated and effective manner in compliance with PSM requirements. Trade Secrets Ensure all information is available to support the PSM Rule. When necessary, confidentiality or nondisclosure agreements may be used. The new pressure relief system must be inspected and tested (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 a DOE facility can be operated safely in a manner that adequately protects workers, the public, and the environment. Unmitigated releases are compared against the evaluation guidelines to determine whether they challenge those guidelines. PrHAs are conducted to identify all process hazards and to evaluate the adequacy of control measures for each hazard. As discussed in 3 DOE-HDBK-1101-2004 Consequence Low Medium High Lab Standard IH C V Monitoring & Control HAZWOPER HAZCOM hemical Inventory & Tracking Fire Prevention & Protec oluntary Protection Program PSM Rule tion EPA Risk Mgmt Program Explosives & Hazardo Materials Handling us Figure 1.1 Chemical Safety Programs Related to Accident Consequence 4 DOE-HDBK-1101-2004 Section 2.3, PrHAs may be used to support development of SARs. SARs may incorporate information on many or all PSM elements. However, the minimum requirements for the PSM Rule must be met if the SAR is to be the source of PSM documentation for a covered process. 1.2 Background Historically, chemical process hazards within the DOE complex have been considered relatively minor compared to nuclear hazards. Prior to the promulgation of the PSM Rule, HHCs were generally viewed as standard industrial hazards unless they could potentially affect the nuclear inventory of a facility. Thus, consideration of chemical releases in safety analysis documents is a relatively recent practice within DOE. DOE policies and Orders have not provided an integrated approach to chemical process safety management. While some PSM elements were in place within DOE, they were designed for nuclear rather than chemical process safety. The PSM Rule, which was issued February 24, 1992, addresses chemical process hazards by redefining the minimum management program requirements for quantities of certain HHCs that equal or exceed specified threshold quantities (TQs). DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, requires that covered chemical processes within DOE comply with the PSM Rule. In June 2004 the DOE sent the Office of Management and Budget, DRAFT 10 CFR 851 “Worker Safety and Health” for subsequent publication in the Federal Register as the new DOE Worker Safety and Health Rule. This new Rule will require contractors to follow all applicable portions of 29 CFR 1910. Where DOE contractors have processes covered by the PSM Rule, all PSM elements must be in place prior to process startup. The PSI and PrHA elements must be updated and revalidated at least every five (5) years after the completion of the initial process hazard analysis to assure that the process hazard analysis is consistent with the current process. Refresher training and compliance audits must be completed at least every three years following the initial refresher training and audits.

1.3 Application The PSM Rule applies to “processes” rather than to “plants” [Q1, Q2, Q3]. The definition of process given in the glossary indicates that chemical quantities in distinct and separate processes may be compared individually, rather than collectively, to the threshold quantity (TQ) [Q4, glossary definition of process]. The PSM Rule applies to any process that meets the following criteria. • The process contains the specified TQ or more, by weight, of any of the 137 listed HHCs [Q5, Q6, Q7]. (OSHA’s toxic and reactive HHCs and their respective TQs are provided in Appendix A.) • The process contains 10,000 pounds or more of a flammable HHC (liquid or gas, or mixture of flammable liquids or gases) [Q8, Q9], in one location, with the following exceptions. 5 DOE-HDBK-1101-2004 1) When a hydrocarbon fuel is used exclusively onsite, the PSM Rule does not apply so long as the fuel is not a part of a process containing another highly hazardous material covered by the Rule [Q10]. 2) The PSM Rule also does not apply to flammable liquids that are stored in atmospheric tanks [Q11, Q12, Q13, Q14, Q15] or transferred through associated piping when those liquids are kept below their normal boiling point without benefit of chilling or refrigeration. Atmospheric storage tanks containing flammable liquids are not exempt if they are located close enough to a covered process that they could be involved in a catastrophic release [Q16, Q17]. Similarly, flammable liquids stored in barrels and drums, would be exempt from coverage so long as they are not stored in such close proximity to a covered process that an incident in that process could involve the containers [Q18]. Where this exemption is invoked, the boiling point (or 10% point of distillation) of the flammable liquid, and its proximity to and absence of interconnections with other covered process equipment should be documented. • The process involves any quantity of an explosive or pyrotechnic HHC in a manufacturing process. Storage and use of explosives outside the manufacturing process are covered by 29 CFR 1910.109 [Q15]. Compliance with the DOE Manual 440.1-1, DOE Explosive Safety Manual, should promote compliance with the PSM Rule, but does not preclude the need to comply with the PSM Rule as well [Q19, Q20]. In addition to the instances cited above, the PSM Rule does not apply to the following situations. • Retail facilities (at which over half of the income is obtained from direct sales to end users). • Oil or gas well drilling or servicing operations. The PSM Rule may apply to other operations associated with drilling, such as separation or treatment of flammable liquids and gases produced by these wells [Q21]. OSHA has determined that DOE petroleum reserves must comply with the PSM Rule. • Remote facilities that are normally unoccupied [See glossary definition of normally unoccupied remote facility). Figure 1.2 provides a general logic diagram for determining the applicability of the PSM Rule in DOE. No documentation for exclusion is required by the Rule. However, DOE contractors should maintain a list of covered processes and, where the Rule is subject to interpretation, document the basis for excluding a process [Q23]. Questions Note: Where OSHA speaks of employers, this Handbook uses DOE contractors. Where OSHA speaks of contractors, this Handbook uses subcontractors. 1. Does the calculated process inventory for a specific HHC apply to an entire plant, or is each process unit viewed as a separate location?

6 DOE-HDBK-1101-2004 Each process should be evaluated separately to determine whether it is covered by the Rule. If several distinct and separate processes use the same HHC, coverage is determined by comparing the maximum intended inventory of each process to the appropriate TQ for the HHC. DOE contractors should not add up the inventory of all processes to determine whether the facility is covered. Compliance is Required if You . . . Yes Figure 1.2 Applicability of the PSM Rule 7 DOE-HDBK-1101-2004 2. If a plant has only one process covered by the Rule, must the PSM Rule be applied to all process areas in the plant? No. A plant may have some process areas that are covered by the PSM Rule and others that are not. PSM provisions are invoked for covered processes only. However, DOE contractors may choose to implement certain PSM elements in areas not covered by the Rule if they believe activities in these areas pose a significant hazard. To avoid regulatory confusion, contractors should document those parts of their plants that are covered processes. 3. Can a facility contain more than one process? A facility can contain several processes. If multiple processes are interconnected, they may be considered a single process under the PSM Rule. 4. To determine whether a process is covered, should DOE contractors compare the OSHA TQ for an HHC to the amount of the chemical annually consumed by the process, or to the maximum intended inventory? DOE contractors should determine whether a process is covered based on the maximum intended inventory that the process can contain (tank or vessel capacity plus interconnected piping capacity), rather than on its cumulative, annual use. Contractors who wish to maintain the quantity of an HHC below its TQ limit, in a process capable of containing over the TQ, must be able to demonstrate that they have effective measures in place to ensure that the inventory in the process cannot exceed the TQ. 5. Several HHCs are listed in Appendix A along with a minimum threshold concentration. What is the technical basis for the list and these thresholds? The Appendix A list was drawn from several sources, including lists prepared by States that have enacted similar regulations. In determining TQs and threshold concentrations for the Appendix A HHCs, OSHA used an approach similar to that used by the State of Delaware. For example, in evaluating toxic materials, OSHA assumed a ground-level, continuous, steady state release for 1 hour. They also used neutrally buoyant Gaussian dispersion modeling with a 4.3 m/s (14.1 ft/sec) wind speed, D-class stability, and urban dispersion coefficients. The preamble to the PSM Rule discusses all of the specific assumptions used by OSHA for its technical basis for toxic and reactive materials in Appendix A. In developing its Recommendation for Process Hazards Management of Substances with Catastrophic Potential, the Organization Resources Counselors, Inc. (ORC) compiled a list of dangerous toxic substances from a number of hazardous substance lists. This compilation was then ranked by calculating the substance hazard index (SHI) for specific concentrations. The SHI is defined as the substance vapor pressure (in mm Hg) at 20 oC multiplied by 1,000,000, divided by 760, and divided by an acute toxicity concentration for the substance. The priority cutoff for the list of toxins in ORC’s recommendations was 5,000. To be consistent with the technical basis for toxic materials submitted by ORC to OSHA, the threshold concentration listed in Appendix A should correspond to an SHI of 5,000. Where the concentrations specified for HHCs do not correspond, they reflect judgments made by OSHA during the rulemaking process.

8 DOE-HDBK-1101-2004 6. How will the list of covered toxic and reactive chemicals found in Appendix A and their TQs be updated? The list of HHCs can be revised through the normal OSHA rulemaking process. Other than corrections for typographical errors, OSHA has indicated no firm plans to change the Appendix A HHCs. 7. How do DOE contractors determine if a process is covered, when an Appendix A chemical is contained in a mixture? Do you calculate the mass of the Appendix A chemical in the mixture and then compare it to the TQ for the pure HHC listed in Appendix A? The substances listed in Appendix A without specified concentration limits are intended to be covered by the PSM Rule at commercial grade percentages purity. The commercial grade of most of the HHCs is approximately 99% pure. Many of the HHCs, if not actually 99% pure, are only one to two percent less than 99% pure. For example, the commercial grades of acrolein and allyl chloride are 97% pure. However, some of the HHCs are considerably less than 99% pure. For example, the commercial grade of hydrogen fluoride is 70%. OSHA defines commercial grade as a typical maximum concentration of a chemical that is commercially available, and shipped. The term commercial grade includes reagent grades that, in some cases, differ in concentration from the typical commercial grades. In cases where different concentrations for commercial and reagent grades are typically shipped, the lowest (or lower) concentration (and any concentration greater) is covered by the PSM Rule. Where covered, the total mass of the mixture is used for comparison with the applicable TQ. 8. Are processes involving flammable liquids (e.g., ethyl alcohol) covered by the PSM Rule? Processes involving flammable liquids (e.g., a distillation process) in quantities at or above 10,000 lb. are covered. Flammable liquids in atmospheric storage tanks are considered a part of a process if the storage tanks are interconnected with the process, or if they are sufficiently near the process that an explosion, fire, or release could reasonably involve the storage area. Flammable liquids that are stored in atmospheric tanks in a tank farm where only transferring and storage are performed are not covered by the PSM Rule. They are, however, covered under 29 CFR 1910.106. 9. Two flammable chemicals in quantities below 10,000 lb are combined in a process to form a flammable liquid in excess of 10,000 lb. Is this process covered? Based upon this consideration alone, yes. 10. Are processes covered if they contain fuel used for process heating or drying only? The PSM rule exempts processes using flammable liquids or gases solely as fuels in the workplace. Thus, these processes are not covered unless they are covered for other reasons. 9 DOE-HDBK-1101-2004 11. There is an exemption for atmospheric storage and transfer of flammable liquids. Are all atmospheric vessels excluded from coverage? This exemption deals with storage and transfer of flammable liquids only. Atmospheric storage and transfer of HHCs listed in Appendix A are not exempt. Further, atmospheric storage tanks of flammable liquids may be covered if they are interconnected or in close proximity to a covered process. Contractors should evaluate each situation based on local site-specific considerations and document the technical basis for invoking this exemption. 12. Are activities such as atmospheric mixing, and blending of flammable liquids covered under the Rule?

The requirements of the PSM Rule apply to such operations. The exemption for atmospheric storage and transfer of flammable liquids does not apply to mixing and blending operations, because such operations may generate static charges capable of ignition. 13. Are flammable liquids covered by the Rule when stored at atmospheric pressure in tanks designed for pressure-service? The Rule exempts storage of flammable liquids in atmospheric storage tanks in certain instances. If a DOE contractor can reasonably show that the tank cannot be operated above atmospheric pressure, then the exemption can still apply. The means to ensure adherence to this operating practice should be reliable and documented. 14. Are flammable liquid storage tanks that are gas-blanketed for vapor control, covered by the PSM Rule? Under the PSM Rule, an atmospheric storage tank means a tank which is designed to operate at pressures from atmosphere through 0.5 p.s.i.g. Therefore, flammable liquid storage in tanks in which gas blanketing is maintained at or below 0.5 p.s.i.g. is exempt if it is not connected to a covered process. Tanks containing 10,000 pounds or more of a flammable liquid are covered by the PSM Rule if they are gas blanketed at a pressure greater than 0.5 p.s.i.g. 15. Are warehouses that store HHCs considered covered processes if the total inventory exceeds the TQ for Appendix A materials? For flammable materials? For explosives? Warehouses are covered by the PSM Rule if the total quantity of an HHC stored in one location exceeds the TQ for the particular HHC. If a warehouse is used to store containers of Appendix A HHCs and, either individually or collectively, they exceed their TQs, then the warehouse is covered under the PSM Rule. However, atmospheric storage of flammable liquids is covered under other OSHA regulations (e.g., 29 CFR 1910.106) and is not covered under this Rule. Further, explosives manufacturing is covered under the PSM Rule. However, storage and use of explosives outside the manufacturing process are covered under 29 CFR 1910.109, Explosives and Blasting Agents; not under the PSM Rule. 10 DOE-HDBK-1101-2004 16. Does the exemption for flammable liquids in atmospheric storage tanks apply if connected to a process or process vessel? No, it only applies to atmospheric tanks, containers, and pipes used only for storage and transfer (to storage). 17. Are atmospheric storage tanks containing flammable liquids exempt even if they are located adjacent to a covered process? Atmospheric storage tanks containing flammable liquids are not exempt if they are located close enough to a covered process that they could be involved in a catastrophic release. 18. For the purposes of the PSM Rule, does OSHA consider Department of Transportation (DOT) approved containers to be atmospheric tanks? Containers such as 55 gallon drums are considered to be atmospheric tanks. Therefore, storage of flammable liquids in such containers, even if the quantity exceeds 10,000 pounds, would not be covered by the PSM Rule. However, such storage would have to meet the requirements contained in the 1910.106, Flammable and Combustible Liquids. 19. What explosive substances are covered by the PSM Rule? In 1910.109(a)(3), an explosive is defined as any chemical compound, mixture, or device, the primary or common purpose of which is to function by explosion (i.e., with substantially instantaneous release of gas and heat).

20. What is meant by the manufacture of explosives? OSHA considers the manufacture of explosives to mean mixing, blending, extruding, synthesizing, assembling, disassembling, and other activities involved in the making of a product or device which is intended to explode. 21. Are flammable liquid and gas separation vessels associated with oil and gas well drilling and servicing operations exempt? Yes; however, these operations are often closely associated with a variety of vessels used to separate and treat the flammable liquids and gases produced by the wells. Some oil and gas production vessels may be excluded from coverage under the Rule by the atmospheric storage and transfer exemption. However, other vessels associated with oil and gas are covered if the flammable materials are stored above atmospheric pressure and meet the 10,000-lb TQ requirement. 22. Please clarify the definition for the exemption of a normally unoccupied remote facility? What does normally unoccupied mean? How remote is remote? Normally unoccupied means that employees are not permanently stationed at the remote location. This includes those sites where employees make periodic, scheduled visits (e.g., for preventive maintenance, sample collection, equipment calibration, or inspections). Facilities meeting this definition are not contiguous with and must be geographically remote from all other buildings, processes, or persons. There is no minimum distance 11 DOE-HDBK-1101-2004 specified to define remote. DOE contractors should review each situation and document their technical bases for determining whether a process is exempt. No accident at a remote location should have the potential to injure people at locations which are normally occupied. 23. What documentation is needed, if any, to support a DOE contractor's judgment that a particular site, facility, or process is not covered? No specific documentation is required by the PSM Rule concerning the establishment of covered processes. However, DOE contractors should maintain a list of covered processes and document the technical basis for any decision to exclude a process from coverage where the PSM Rule is subject to interpretation. 24. Single containers used to store a specific HHC, each containing less than the TQ amount, are located at several distinct, widely-separated locations in a plant. Is the storage and handling of this HHC covered under the Rule if the combined amount of two or more containers exceeds the TQ for the HHC? If the containers are not connected and are not in one location, then each container and its associated process should be evaluated separately. On the other hand, if widely separated containers are connected by process piping, and a loss of containment in one section could cause an HHC to be released from more than one container, then coverage should be evaluated on the basis of the total amount of HHC in all of the connected containers. A similar argument applies if these separate containers, although unconnected, are all stored in one location where a single, common event could release the HHC from two or more containers. 25. Does the PSM Rule apply to onsite movement of HHCs in containers, trucks, or railcars? The PSM Rule applies to the onsite movement and storage of HHCs in containers or vehicles operated by employees. Onsite and offsite movement of HHCs by commercial carriers is regulated by other agencies such as the U.S. Department of Transportation (DOT), the Office of Pipeline Safety, and the U.S. Coast Guard.

For example, a railroad tank car is subject to PSM requirements if it contains more than the TQ of an HHC. However, the exception for flammable liquids stored in atmospheric tanks or transferred below their normal boiling point without the benefit of chilling or refrigeration may apply so long as the rail car is not pressurized. 26. A process contains a material not covered by the PSM Rule. However, release of this material to the atmosphere in sufficient amounts would generate (e.g., through oxidation, fire, reaction with moisture, etc.) an HHC in excess of its TQ. Is this process covered? A process is not covered under the PSM Rule unless it contains an HHC that exceeds its TQ. However, when DOE contractors recognize situations with significant potential impacts to workers, the public, the environment, or facilities and operations; they should consider applying appropriate PSM safety management elements. 12 DOE-HDBK-1101-2004 27. A process normally contains no HHCs, but under upset conditions, the process could generate an HHC in an amount in excess of the TQ. Is the process covered? Processes are covered by the Rule only if, at any time under normal processing circumstances, they contain an HHC in excess of its TQ. The ability to generate an HHC during an upset condition does not invoke coverage by the PSM Rule. However, when DOE contractors recognize situations with significant potential for safety and health impacts, they should consider applying appropriate PSM practices to protect worker health and safety. 28. An Appendix A chemical is created within and then immediately consumed in a process. Does the brief existence of this short-term intermediate chemical cause this process to be covered by the Rule? If the inventory of this intermediate can only exceed the TQ under upset conditions, is it a covered process? A process is covered if, at any time in one location, it contains an HHC in excess of its TQ. This process is covered as long as the intermediate existed under normal conditions in the process. If the intermediate chemical could exist above the TQ only under upset conditions, then the process is not covered. However, when DOE contractors recognize situations with significant potential for safety and health impacts, they should consider applying appropriate PSM practices to protect worker health and safety. 29. Please clarify the exemptions for the following types of operations covered under the workplace fuel criteria: hazardous waste incinerators, refinery fuel gas systems, liquefied petroleum gas (LPG) storage for vehicle fueling, natural gas systems for utility boilers, and natural gas systems used to sweep flare systems. If the incinerator is used to destroy either a flammable material or another HHC that is listed in Appendix A, and the process contains a TQ of an HHC, the incinerator is covered. Generally, fuel gas or natural gas systems are exempt if they are operated only for fueling process furnaces or utility boilers that are also not covered. However, if fuel gas or natural gas is used to fuel a covered process, then the fuel gas or natural gas systems associated with the process are covered. LPG storage and handling systems used exclusively to fuel vehicles are not covered. A natural gas supply used to “sweep” a flare system is not covered unless the flare system is covered for other reasons. 30. Must the boundary of a covered process containing many interconnected vessels always extend in all directions to the process unit’s battery limits?

No. In many cases, DOE contractors may wish to define the physical limits of coverage based on an evaluation of the threat of a catastrophic release of an HHC. Contractors are encouraged to document the technical basis of their coverage decision for those cases subject to interpretation. 31. A continuous process uses an HHC, but the HHC inventory exceeds the TQ in only one vessel. Upstream of this vessel, except for the HHC supply system, there are no HHCs. Because the HHC is consumed almost entirely in the vessel, normally only trace amounts of the HHC exist downstream of this vessel. Is this process covered, and if so, how far upstream and downstream do the covered process boundaries extend? 13 DOE-HDBK-1101-2004 This process is covered. DOE contractors may wish to adopt the following approach. Extend the boundary upstream and downstream to the point at which there is no reasonable potential for a catastrophic release. At least the equipment immediately upstream and downstream from the vessel containing the TQ of the HHC should be included in the boundaries of the process. 32. A batch process uses an HHC, above its TQ, in one of its many processing steps. Is this step, and its associated equipment, a covered process? Yes. In addition, the same strategy discussed in Questions 30 and 31 may apply to the equipment used in a batch process. A DOE contractor may apply a similar approach in setting the boundaries around the processing steps that are covered under the Rule. 33. Must the inventory of HHCs contained in offsite interconnecting pipelines be included in the inventory calculation? If so, can reliable isolation devices at the fence line be used to limit the inventory used in the coverage calculation? DOE contractors should consider the amount of material that could reasonably be released if a loss of containment occurred onsite. If this amount represents a catastrophic release to the workplace (i.e., it exceeds the TQ for an HHC), then the process is covered. OSHA has not yet recognized the use of isolation devices as adequate mechanisms to limit inventories for purposes of determining coverage under the PSM Rule. However, if isolation devices are considered as preventative or mitigative control measures against catastrophic releases, then documentation should be provided as to their effectiveness and reliability. 34. Does the PSM Rule apply to laboratory and research operations? A laboratory or research operation involving at least the TQ of one or more HHCs is subject to the PSM Rule. 35. Does the PSM Rule apply to EPA regulated and permitted Resource Conservation and Recovery Act (RCRA) hazardous waste treatment, storage, and disposal (TSD) facilities, when such facilities keep onsite in one location a hazardous waste chemical in a concentration and quantity that exceeds the applicable TQ of Appendix A. Yes. Contractors having TSD facilities which contain covered processes must comply with the PSM Rule. 14 DOE-HDBK-1101-2004 2.0 Process Safety Management Elements The PSM Rule describes a comprehensive management system containing 14 elements for effective control of process hazards. The word system implies the integration of all management elements with a method for assessing the efficiency and effectiveness of implementation. The elements of the PSM Rule discussed in this section are an interrelated set of management systems associated with the process, people, production, and preparedness, as shown in Figure 2.1.

This section describes the intent of each element; corresponding DOE programs and requirements; documentation requirements; and minimum implementation criteria for development of new programs or evaluation of existing ones. Where DOE Orders are referenced, associated DOE Manuals and Contractor Requirement Documents should also be consulted. DOE contractors can use the implementation criteria to determine when the requirements of the element are satisfied. Each section concludes with questions and answers based on OSHA's interpretation of the PSM Rule. Appendix C compares the elements of the PSM Rule with the provisions of the EPA's Risk Management Program. Figure 2.1 The Process Safety Management System 15 DOE-HDBK-1101-2004 2.1 Employee Participation 29 CFR 1910.119 (c) (1) Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph. (2) Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard. (3) Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard Intent Recent enforcement actions indicate that OSHA expects employers to consult with employees and their representatives on each PSM element (including development of the employee participation plan) [Q36, Q37]. Employees with a working understanding of chemical processes should serve as informational resources in the development of chemical process accident prevention plans, the performance of PrHAs, and the conduct of incident investigations and audits. As a minimum, employees and their representatives must be consulted (i.e., information exchanged and input solicited) [Q38, Q39]. The effectiveness of PSM programs depends on the employees' sense of ownership and accountability. DOE contractors should work with employees and their representatives to reach agreement on and to document the optimum level of employee involvement for each element. Contractors must also ensure that workers have access to PrHAs and PSI to promote the safety of day-to-day operations [Q40, Q41]. Corresponding DOE Programs and Requirements General areas for employee participation in DOE safety and health programs are identified in DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES. Documentation Requirements Contractors are required to prepare written plan for worker involvement. The plan must address the minimum requirements for consultation on development of PrHAs and other PSM elements. It must also address worker access to PrHAs, PSI, and all documentation developed under the PSM Rule. A sample employee involvement program is included at the end of this section in Exhibit 2.1. Minimum Implementation Criteria DOE contractors must develop a plan that provides for an appropriate level of employee participation in the conduct of each PSM element (e.g., consultation with workers on PrHAs, employee access to PrHAs and PSI, and training). 16 DOE-HDBK-1101-2004 Questions 36. Please clarify the definition of employee. Does the PSM Rule mean hourly, salaried, or both? Under the PSM Rule, OSHA normally considers an employee to be an hourly worker who is directly involved with a covered process. However, DOE encourages full worker participation, including subcontractor, hourly, and exempt workers.

37. What are acceptable levels of employee participation? Must employees participate in all PSM elements? What documentation is required to demonstrate participation? DOE contractors should decide the appropriate level of employee involvement in PSM activities based on site-specific conditions and consultation with employees. Although the PSM Rule requires no specific documentation of employee involvement beyond that specified in the written plan, the degree of employee participation should be evident in such PSM documentation as PrHA reports and minutes of safety meetings. 38. How do DOE contractors consult with employees and their representatives at a non-union facility? DOE contractors may provide a broad spectrum of possibilities for employee participation in various PSM activities. They may also create management/employee committees to address site PSM and safety and health issues. 39. The PSM Rule requires contractors to consult with employees and their representatives. Is the term broad enough to include representatives of international unions or consultants designated by the union locals or international? The term employee representative means a union representative where a union exists, or an employee-designated representative in the absence of a union. The term may include the local union representatives, international union representatives, or individuals designated by these parties, such as safety and health committee representatives at the sites or non-employee consultants. In the absence of a union, employees may designate a representative to participate in the consultation process. 40. What does access mean? Does access refer to availability at a central location? Do DOE contractors have to make copies for employees if requested? Access under the PSM Rule means that information must be made available for employees and their representatives in a reasonable manner. Reasonable access may require loaning documents or placing copies in more convenient places than a central location. The trade secret provision of the Rule permits contractors to require confidentiality agreements when needed. 41. What does access to PrHAs mean? Employees working in a covered process area should be able to review a PrHA report on the process. 17 Exhibit 2.1 DOE-HDBK-1101-2004 SAMPLE EMPLOYEE PARTICIPATION PLAN PURPOSE The purpose of this plan is to document the program elements used by (Contractor/Site) to: a) consult with employees and their representatives, where applicable, on the development of the various elements contained within the OSHA Process Safety Management Rule (29 CFR 1920.119) and b) provide employees and their representatives access to information developed under this Rule. GENERAL The intent of this program is to foster broad and active participation involving hourly, exempt, nonexempt, and contract employees cooperating to make the workplace safer. Consistent with this intent, site management will do the following. a) Inform employees about the promulgation of the OSHA PSM Rule and its contents, using currently established communication methods. b) Assess compliance status and develop specific plans to ensure that the PSM Rule is effectively implemented, and communicate this information to employees as appropriate. c) Identify operations (processes) covered under the requirements of the rule and communicate these findings to employees.

d) Inform employees of the relevancy and applicability of existing company safety elements to satisfying the requirements of the PSM Rule. e) Involve employees in compliance with the various elements within the OSHA PSM using their knowledge, skills, and experience. f) Encourage employees to submit safety suggestions via an existing safety/operations/quality improvement suggestions system. EMPLOYEE INVOLVEMENT BY PSM PROGRAM ELEMENT This section describes opportunities for employee involvement in specific PSM elements. (Detailed descriptions of program elements and their requirements are provided in the later sections of this handbook. This section provides samples of employee involvement in a few PSM elements. DOE contractors should examine each PSM element for potential opportunities for employee involvement. Employee participation is not required for all PSM elements; just where it makes good sense.) 18 DOE-HDBK-1101-2004 Exhibit 2.1 Process Hazard Analyses (PrHA) Employees participate on the PrHA team or in support of the analysis effort. The results of the PrHA are shared with employees affected by the findings or recommendations. Employees are advised of any necessary changes brought about by the PrHA and may be involved in the design and implementation of required changes. Operating Procedures Employee involvement in the development and implementation of operating, maintenance, and safe work practice procedures may take several forms. • Consultation during development/implementation to determine if procedures accurately reflect what is done, what should be done, and the steps necessary to attain the desired result in a safe and environmentally responsible manner. • Procedure development assignments based on employee knowledge and experience. • Commissioning team assignments to critique and implement new processes or procedures. Training Employees may be involved through self-managed learning, coaching new employees, working with training guides, and one-on-one, on-the-job training in the field. The workplace environment encourages employees to identify training needs and take part in training development and implementation. Pre-startup Safety Review Whenever possible, cognizant employees will be involved in the performance of the PSR. Employees are encouraged to have a questioning attitude and report any concerns that are not addressed by the PSR. Mechanical Integrity Maintenance personnel receive training based on written procedures for the maintenance of process equipment. They must have an understanding of the process and its operation based on applicable operating procedures, an overview of the process, and process hazards, prior to being qualified. Employees typically do much of the work in this area providing input for equipment history and reliability; recording observed data; maintaining the inspection and maintenance database. Employees doing the actual test and inspection work are typically asked to review and comment on manufacturer’s recommendations for testing and inspection approaches and frequencies. 19 DOE-HDBK-1101-2004 Exhibit 2.1 Employees take part in equipment failure reviews, participate in work process critiques, and are encouraged to make recommendations for change. Hot Work Permit (Nonroutine Work Authorizations) Employees are involved in planning and implementing the safe work procedures documented in hot work permits and other nonroutine work authorizations.

Management of Change Procedures exist to manage changes to process chemicals, technology, equipment, procedures, and process facilities. These procedures provide assurance that the PrHA, PSI, and procedures are updated, if necessary, to reflect the changes. Essential to the success of MOC system is the active participation by both site and affected subcontractor employees in the review and evaluation process to determine the impacts of proposed changes. Incident Investigation An incident is an event whose occurrence resulted in, or could reasonably resulted in a catastrophic release of a highly hazardous chemical in the workplace. It is site policy that all incidents will be investigated as soon as possible, but be initiated no later than 48 hours after the incident. The team investigating the incident shall consist of at least one person knowledgeable in the process involved; a contract employee, if a subcontractor was involved; and other cognizant and informed individuals. Employees are typically involved in incident investigations since their knowledge and skills in operations or maintenance are necessary for the conduct of the investigation. When the investigation is completed, a report containing the contributing factors to the incident and recommendations for prevention of future occurrences will be made. This report will be circulated by posting in work areas or by discussing it in scheduled safety meetings or ad hoc meetings with employees. Management then addresses, resolves, and implements the report findings and recommendations. All site and contractor personnel affected by the changes are informed of any changes and may be involved in their implementation. Emergency Planning and Response A formal review process for site-wide procedures exists for soliciting and obtaining employee input on site emergency response plans. Employees may critique drills and actual incidents to identify opportunities for performance improvements, and improve both emergency response planning and responder performance. Communication to employees and subcontractors is essential to promote understanding of the actions to take during an emergency. 20 DOE-HDBK-1101-2004 2.2 Process Safety Information 29 CFR 1910.119 (d) In accordance with the schedule set forth in paragraph (e)(1), the employer shall complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. (1) Information pertaining to the hazards of the highly hazardous chemicals in the process. This information shall consist of at least the following: (i) Toxicity information; (ii) Permissible exposure limits; (iii) Physical data; (iv) Reactivity data: (v) Corrosivity data; (vi) Thermal and chemical stability data; and (vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur.

Note: Material Safety Data Sheets meeting the requirements of 29 CFR 1910.1200(g) may be used to comply with this requirement to the extent they contain the information required by this subparagraph. (2) Information pertaining to the technology of the process. (i) Information concerning the technology of the process shall include at least the following: (A) A block flow diagram or simplified process flow diagram (see Appendix B to this section); (B) Process chemistry; (C) Maximum intended inventory; (D) Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and, (E) An evaluation of the consequences of deviations, including those affecting the safety and health of employees. (ii) Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis. (3) Information pertaining to the equipment in the process. (i) Information pertaining to the equipment in the process shall include: (A) Materials of construction; (B) Piping and instrument diagrams (P&IDs); (C) Electrical classification; (D) Relief system design and design basis; (E) Ventilation system design; (F) Design codes and standards employed; (G) Material and energy balances for processes built after May 26, 1992; and, (H) Safety systems (e.g. interlocks, detection or suppression systems). 21 DOE-HDBK-1101-2004 (ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices. (iii) For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner. Intent The objective of the PSI element is to collect complete and accurate process information sufficient to conduct PrHAs, to support hazard communication requirements, and to document the design configuration of each process [Q42]. PSI must be sufficient to allow assessment of fire, explosion, and toxic hazards; the corrosive or erosive effects of process chemicals on equipment and instrumentation; the potential for overpressures or runaway reactions; and the existence of incompatibilities between materials commonly found around covered processes [Q43]. Information on process technology must describe the process chemistry, maximum inventories of process chemicals, and limits for process parameters. Information is also needed to support a qualitative estimate of the consequences of deviations or upsets outside established process limits. A description of process technology should include block or process flow diagrams. Process flow diagrams may include equipment sizes and ratings, process parameters for each mode of operation in each piping segment, limits on chemical levels in all process vessels, pressure and flow data for pumps, and process temperature and pressure limits for all equipment. Such diagrams may include set points for pressure relief valves and alarms, monitoring and surveillance equipment, and batch size information. Thus, detailed process flow diagrams may contain all required process technology information except process chemistry. However, a simple block flow diagram is adequate if the other necessary information is captured on the P&IDs or in a written process description. For existing processes for which the original process technology information no longer exists, it may be developed in conjunction with the PrHA.

Process equipment information should describe all hardware used in a process and provide the actual or reconstructed design, including all codes, standards, or other good engineering practices that were followed. It must describe materials of construction; electrical classification; and design of pressure relief, ventilation, monitoring and surveillance equipment, and other safety systems. PSI should contain a functional description of the safety systems in a covered process to convey the protective features that exist for emergencies [Q43]. P&IDs, which generally contain more detailed information than process flow diagrams, must be provided to show the relationship between equipment and instrumentation. Information on new processes must also include material and energy balances. For older processes where the design basis is unknown or the standards, codes, and practices are not in general use, documentation must be developed to show that the equipment is still safe to use. Corresponding DOE Programs and Requirements 22 DOE-HDBK-1101-2004 Most DOE contractors have hazard communication programs that use information from Materials Safety Data Sheets (MSDSs) to comply with 29 CFR 1910.1200. Information about the hazards posed by most process chemicals may also be obtained from MSDSs. Additional information may be required to describe process chemistry conditions that can lead to overpressures or runaway reactions. DOE information requirements regarding hazard identification are included in DOE O 151.1B, COMPREHENSIVE EMERGENCY MANAGEMENT SYSTEM, DOE O 420.1A FACILITY SAFETY, DOE O 430.1B, REAL PROPERTY ASSET MANAGEMENT, and DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES. Some DOE facilities, especially nuclear facilities, have design information for systems, structures, and components to support Safety Analysis Reports (SARs) and ongoing engineering improvements to systems. Systems for maintaining as-built drawings of processes, together with their original design basis and history of modifications, may be available for these facilities. However, documentation of the design basis for older DOE facilities and nonnuclear facilities is often weak. New DOE facilities are required under DOE O 430.1B to meet certain facility safety requirements. SARs for existing facilities require that the facility design be evaluated for conformance with these requirements. Statements in the design information and/or the SAR regarding compliance with these safety design requirements provide documentation that facilities and equipment are designed in accordance with recognized and generally accepted good engineering practices. DOE information requirements associated with the technology and equipment of a nuclear process are found in 10 CFR 830 Subpart B, NUCLEAR SAFETY MANAGEMENT, SAFETY BASIS REQUIREMENTS. Documentation Requirements The PSI element is a documentation requirement. It specifies the minimum written PSI package needed to support a PSM program. It should be updated as part of the MOC element of the PSM Rule because the safety of processes depends on workers having access to accurate process safety information. PSI used to support the development of facility safety documentation or PrHAs should be referenced. PSI need not be located in one document or in one place [Q42]. Electronic storage media may be used so long as a backup version is available at all times [Q44]. PSI should be part of the facility configuration information and should be maintained for the life of a process through a configuration management system [Q45].

Complete PSI packages are essential for conducting PrHAs. Initial PSI is required to establish risk-based priorities for completion of PrHAs. Minimum Implementation Criteria Adequate information must be available to support preparation of PrHAs, operating procedures, training materials, and emergency plans. The PrHA team can generate information on process technology when complete information does not exist. In addition, documentation must be available to confirm that process equipment complies with recognized and generally accepted 23 DOE-HDBK-1101-2004 good engineering practices. Some of the more frequently used codes and standards include the following. • American National Standards Institute (ANSI) establishes piping/valves/fittings/flanges and equipment design criteria, including selection of materials and standards for engineering drawings • American Society for Testing and Materials (ASTM) establishes standard testing methods and acceptable test results, and definition of metallic and non-metallic material • National Fire Protection Association (NFPA) establishes electrical area classifications and requirements, and fire protection design standards • American Society of Mechanical Engineers (ASME) establishes Boiler and Pressure Vessel Code; welding materials and welder qualifications, NDT requirements, and standards; and ferrous and non-ferrous material specifications • Institute of Electrical and Electronic Engineers (IEEE)/Instrument Society of America (ISA) establishes design and application specifications for electrical and electronic equipment, and failure rate data • The American Petroleum Institute (API) recommended practices govern the design of hydrocarbon systems and facilities, including safety systems and process hazards management guidelines for petrochemical facilities. For existing equipment designed and constructed according to codes, standards, or practices that are no longer in use, a determination must be made and documented that the equipment is designed, maintained, inspected, tested, and operated in a safe manner. The following methods can be used to demonstrate that the equipment is designed for safe operation. • Conduct engineering analyses or empirical testing to show that the equipment design provides a level of protection equivalent to current codes or standards. • Change process parameters to comply with new codes or standards. • Use the PrHA to demonstrate that continued use of existing equipment does not significantly increase the likelihood of catastrophic consequences, compared to equipment designed to current standards [Q46]. Information about process chemical hazards must include the following. • Toxicity information, such as LD50 /LC50 values, Threshold Limit Values (TLVs)), Immediately Dangerous to Life or Health (IDLH) values, and Emergency Response Planning Guideline (ERPG) concentrations. • Permissible Exposure Limits (PELs). • Physical data, such as boiling point, freezing point, density, vapor pressure, vapor density, solubility, evaporation rate, appearance, and odor. • Reactivity data, such as stability and compatibility with other families of materials including acids, bases, and water. • Corrosivity data for containment vessels, metallics, and plastics. 24 DOE-HDBK-1101-2004 • Thermal and chemical stability data, such as flammability limits, flash point, and auto ignition temperature. • Hazardous effects of inadvertent mixing of different materials.

Information about process technology must include the following. • Block flow diagrams or simplified process flow diagrams. • Process chemistry, such as flow rates, chemical equations, chemistry of intermediates, utility systems, and exothermic/endothermic reactions. • Maximum intended inventory for all storage tanks, reactors, and other vessels. • Safe upper and lower limits for process parameters, such as flow rates, pressures, temperatures, levels, phases, and composition, for all modes of operation in all major piping segments. • Consequences of deviations outside safe operating limits. Information about process equipment must include the following. • Materials of construction and basis for selection, such as material compatibility or corrosion resistance. • Electrical area classification, based on flammable materials located near the process. • Relief system design and design basis. • Ventilation system design, including airflow, and psychometric and equipment sizing calculations. • Design codes and standards. • Material and energy balances for processes. The balances must show that mass flows and heat transfers sum properly. • Safety systems, such as control interlocks, depressurization, containment and disposal, and toxic/flammable material detection systems. • Piping and instrumentation diagrams. Questions 42. Must all PSI be kept in one place? Can it be spread out in a variety of documents and locations? All PSI does not have to be in one document or in one place but should be accessible to all employees who need it to safely perform their jobs. DOE contractors may choose to store their PSI in a central location. However, they should ensure that this level of document control does not hamper worker access to up-to-date PSI. DOE contractors may consider developing a PSI road map to help workers find necessary information easily. 43. PSI is required for ventilation system design, safety systems, and mixing of materials that could foreseeably occur. What is meant by these terms? 25 DOE-HDBK-1101-2004 PSI should contain a description of the function and design basis for all ventilation systems whose purpose is to maintain a healthy environment, particularly when these ventilation systems are used to maintain a safe haven in the event of a catastrophic release of a HHC. PSI should contain a functional description of the safety systems in a covered process. Safety systems are systems designed to control and maintain a process within safe design parameters. Examples of safety systems are interlocks, scrubbers, flares, and detection systems for releases of toxic or flammable chemicals. Workers should know what protective features exist and how to use these safety systems in an emergency. Chemical hazard information should contain information on the incompatibility of HHCs with materials that are known to exist in the workplace. Employees routinely working with materials commonly found around a covered process should be familiar with the potential safety and health impacts from inadvertently combining these materials with the HHC. 44. Do we have to keep hard copies of all of the PSI or can we use electronic media? There is no specific storage requirement for PSI or any other documentation created under the PSM Rule. Any medium may be used as long as the accessibility requirements are met. However, DOE contractors who use electronic storage media should consider in advance what they will do when computers used to access this information are unavailable (e.g., during power failures).

45. How long must DOE contractors maintain process safety information? To demonstrate compliance and to meet the intent of the PSM Rule, PSI must be kept for the lifetime of a process and updated whenever changes other than replacement in kind are made. 46. How can a PrHA be used to demonstrate that equipment is designed safely? The PrHA can be used to perform a sensitivity analysis to evaluate the impacts of using equipment or facilities which have not been designed to current codes and standards. 26 29 CFR 1910.119 (e) DOE-HDBK-1101-2004 2.3 Process Hazard Analysis 29 CFR 1910.119 (e) (1) The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. Employers shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. The process hazard analysis shall be completed prior to process startup. (2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. (i) What-If; (ii) Checklist; (iii) What-If/Checklist; (iv) Hazard and Operability Study (HAZOP); (v) Failure Mode and Effects Analysis (FMEA); (vi) Fault Tree Analysis; or (vii) An appropriate equivalent methodology. (3) The process hazard analysis shall address: (i) The hazards of the process; (ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; (iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors.); (iv) Consequences of failure of engineering and administrative controls; (v) Facility sitting; (vi) Human factors; and (vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. (4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. (5) The employer shall establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. 27 DOE-HDBK-1101-2004

(6) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process. (7) Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section, as well as the documented resolution of recommendations described in paragraph (e)(5) of this section for the life of the process. Intent PrHA is a systematic method to identify and assess process hazards, and is the cornerstone of a PSM program. PrHAs can be used to identify causes and consequences of potential accidents associated with equipment, instrumentation, utilities, human performance, external factors, and natural phenomena such as earthquakes. The objective of PrHA is to determine areas of excessive risk where preventative and mitigative measures may be warranted to better control the hazards. PrHAs can help identify accident scenarios leading to worker injuries or fatalities, property damage, public exposure to chemicals, environmental impacts, or other adverse consequences. Corresponding DOE Programs and Requirements General Guidance DOE-HDBK-1100-96, Chemical Process Hazards Analysis, provides detailed information on PrHA methodologies and the PrHA process. DOE guidance available to support the process hazard analysis team includes DOE/EH-0340, Example Process Hazard Analysis of a Department of Energy Water Chlorination Process. Safety Analyses DOE O 430.1B, REAL PROPERTY ASSET MANAGEMENT, requires a preliminary safety assessment as part of the project management system prior to execution of design plans. DOE requires that hazard analyses be performed to support SARs under 10 CFR 830 Subpart B NUCLEAR SAFETY MANAGEMENT, SAFETY BASIS REQUIREMENTS and DOE-STD-1027-92 (CH-1). PrHAs will not replace SARs, nor will SARs replace PrHAs; they are conducted to satisfy two independent sets of requirements. Therefore, conduct of a PrHA does not necessarily mean that a SAR must be performed or vice versa. However, because a PrHA is a systematic method to identify accident scenarios, it may be used as an integral part of the overall hazards analysis required in the development of a SAR, when a SAR is necessary. When the PrHA is used to support the SAR, all PSM documents used to develop the PrHA should be referenced in the appropriate SAR chapter. References and summaries should include not only the results of the PrHA, but also all documents concerning the resolution of the PrHA team’s findings. OSHA requires that PrHAs address facility sitting issues (e.g., the physical spacing between processes, or between a process and administrative facilities). Consideration of natural phenomenon hazards is also an appropriate sitting issue, especially for new proposed facilities. 28 DOE-HDBK-1101-2004 DOE O 420.1A, FACILITY SAFETY, identifies safety analysis requirements for various types of facilities and requires consideration of natural phenomena hazards relative to facility sitting. DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, describes general hazard identification and analysis requirements for occupational safety and health.

Emergency Planning DOE O 151.1B, COMPREHENSIVE EMERGENCY MANAGEMENT SYSTEM, requires hazard identification as the basis for emergency planning. PrHAs have direct application for identifying chemical process hazards in support of emergency planning as required by DOE O 151.1B. They should be used to support the emergency planning element in the PSM Rule in conjunction with consequence modeling. PrHAs, SARs, and emergency planning hazard analyses should be combined to satisfy all program requirements whenever possible. MOC If the PrHA identifies an issue that leads to a change in procedures, drawings, or design, the change must be submitted through the facility’s MOC systems. If the PrHA identifies an issue that falls outside the safety envelope for a facility, that issue should be treated as a potential unreviewed safety question as described in 10 CFR 830 Subpart B NUCLEAR SAFETY MANAGEMENT, SAFETY BASIS REQUIREMENTS and DOE G 424.1-1, IMPLEMENTATION GUIDE FOR USE IN ADDRESSING UNREVIEWED SAFETY QUESTION REQUIREMENTS. Documentation Requirements Written PrHAs, updates and revalidations, and documentation of resolutions to recommendations must be kept for the life of a process and reviewed every five years. The PrHA may be a stand-alone document or an attachment used in conjunction with facility safety documentation. A PrHA report should identify the PrHA team members, the processes analyzed, the PrHA method used, and the manner in which required PrHA issues were addressed. Other documentation to support the review depends on the method selected, the covered process, and the particular needs of the facility [Q53]. Minimum Implementation Criteria This section provides a summary of the minimum implementation criteria for the PrHA element. DOE-HDBK-1100-96, Chemical Process Hazards Analysis, addresses the PrHA element of the PSM Rule in detail. Schedule PrHAs must be completed by risk-priority, based on a relative ranking of the risks of the covered processes [Q54]. This ranking must consider the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process. The basis for this ranking must be documented [Q55]. DOE contractors must complete the required PrHAs prior to process startup [Q56]. PrHAs must be reviewed and updated at least every 5 years and retained for the life of the process [Q57,Q58,Q59]. Team PrHAs must be performed by a team having the following mandatory qualifications. 29 DOE-HDBK-1101-2004 • At least one individual with expertise in engineering and process operations. • At least one individual with specific process experience. • A team leader knowledgeable in the methodology. A PrHA team is usually composed of two to five members and may include a safety engineer or analyst, a process engineer, a maintenance supervisor, a operations supervisor, a facilities engineer, or other members with needed expertise. At a minimum, the team leader should be able to properly and impartially use the selected PrHA methodology. There are no specific requirements for PrHA leader qualifications or for documenting the qualifications of team members. However, brief resumes of team members should be included in PrHA documentation. Detailed classroom training on PrHA methods is an appropriate way for team members to gain knowledge about specific PrHA methods. Contractors may elect to compile a list of PrHA-qualified individuals at a facility along with their PrHA experience [Q48].

Method Selection of an appropriate PrHA method depends on several factors including the complexity of a process, historical and industry information about the process, and process stability. Selection of the methodology must be consistent with the process being analyzed. One or more of the following methodologies, or an appropriate equivalent methodology, must be used. The PSM Rule allows other equivalent analysis methodologies to be used if they are systematic and appropriate for the level of complexity of the process [Q47]. • What if • Checklist • What if/checklist • HAZOP • FMEA • Fault Tree Analysis. DOE contractors should refer to appropriate industry references such as CCPS’s Guidelines for Hazard Evaluation Procedures, Second Edition with Worked Examples for more information about appropriate, equivalent PrHA methodologies. Descriptions of PrHA methods are also provided in DOE-HDBK-1100-96, Chemical Process Hazards Analysis. The PrHA process is generally divided into three phases: information gathering; conduct of the PrHA and development of recommendations; and resolution. PSI should be developed prior to initiating a PrHA or as part of the PrHA process. During the PrHA, the team must identify process hazards; review the accident history of the process to identify process hazards, accident precursors, lessons learned, and trends; consider the impacts of human factors; identify engineering and administrative control measures and their interrelationships; determine the consequences if those control measures fail, taking facility sitting into consideration; and determine the qualitative range of safety and health effects on employees at the worksite [Q49]. In developing the PrHA, the team must consult with any subcontractor employees involved in the operation or maintenance of the process. The PSM Rule requires DOE contractors to address in the PrHA previous incidents at their facilities that had a potential for catastrophic effects in the workplace. Under the incident 30 DOE-HDBK-1101-2004 investigation provision of this Rule, contractors are required to retain incident reports for 5 years, the time between PrHA updates. Although there are no requirements to consider incidents that occurred outside a facility, DOE contractors should review and consider relevant incidents that have occurred elsewhere in their company, in the DOE complex, or in industry [Q50]. Determining the impacts of human factors requires considering the degree to which process safety depends on human performance; whether workers can reasonably be expected to perform the tasks they are assigned; and whether procedures and training adequately guide and prepare workers to perform tasks correctly. The human factors assessment in a PrHA could include listing potential human-error causes of accidents; examining the location of and access to critical safety instruments, alarms, and equipment; or reviewing critical procedures used by operators and maintenance personnel. For critical operations, it may be necessary to perform task hazard analyses to analyze the operator/machine interface in process control rooms or other work locations to adequately evaluate human factor impacts [Q52].

Addressing facility sitting in a PrHA means considering the physical location of covered processes within the plant property. A PrHA team should consider the proximity of the covered process to workers and egress routes when evaluating the potential safety and health impacts of possible HHC releases. The team must also consider the impact of vehicle traffic and adjacent operations on the safety of the process. Possible facility sitting issues include the location of vessels containing HHCs and their proximity to other equipment, control rooms, maintenance shops, and administration buildings [Q51]. Resolution of Recommendations Process hazard analysis is not an end in itself. It is a method to identify areas of excessive risk. Therefore, a tracking system must be in place to ensure that the findings and recommendations of the PrHA team are resolved in a timely manner, that actions taken are documented, and that all affected operating and maintenance workers are made aware of these actions. This system must ensure that: • findings and recommendations are addressed promptly • recommendations are resolved and documented • actions are completed as soon as possible • a schedule for all resolutions is established and followed • actions are communicated to employees affected by any changes. Resolution of recommendations should be accomplished through a MOC system. In any case, contractors should develop a schedule for completion of corrective actions and document the basis for the amount of time needed [Q52]. The PrHA team's findings and recommendations must be addressed and resolved. However, DOE contractors may reject a recommendation where it can be documented that one of the following conditions is true. • The recommendation is based on factual errors. • The recommendation is not necessary to protect health and safety. • An alternative measure can provide a sufficient level of protection. • The recommendation is infeasible. 31 DOE-HDBK-1101-2004 Questions 47. What characteristics does an “appropriate equivalent methodology” need to be considered acceptable for performing a PrHA? Any technique or combination of techniques used to perform a PrHA must address the issues specified in this provision (e.g., the extent of hazards, the qualitative description of range of consequences). Moreover, the methods should generate the types of results and documentation required by the Rule (e.g., a list of recommendations). Beyond these criteria, a PrHA method should help ensure a thorough evaluation of potential safety and health impacts from process equipment failures and human errors. 48. What training/experience is necessary for a member of the PrHA team to be considered knowledgeable in the selected PrHA methodology? What documentation is required? Knowledge of the PrHA method selected for use for a particular process is required for only one member of the PrHA team. There are no specific requirements for PrHA qualifications or for documenting the qualifications of PrHA team members. Detailed hands-on classroom training on PrHA methods is an appropriate way for team members to gain necessary knowledge of a specific PrHA method. Previously demonstrated experience in the use of the technique may also be accepted as sufficient "qualification" for PrHA team leaders. Contractors may elect to compile a list of PrHA-qualified individuals at a facility along with their PrHA experience.

49. If batch processes involve hundreds of recipes and chemicals, must a separate PrHA be performed on each recipe, or can these PrHAs be done generically? PrHAs for batch processes that use a variety of chemicals and recipes can be performed on a generic basis as long as the chemicals and recipes represent the full range of possible processing circumstances, including worst case situations. The technical basis for this worstcase selection of circumstances should be documented. 50. Is identification of previous incidents restricted to the specific facility or must DOE contractors conduct an industry-wide search for incident information? The PSM Rule requires DOE contractors to address in the PrHA previous incidents at their facilities that had a reasonable potential for catastrophic effects in the workplace. Although there are no requirements to consider incidents that occurred outside a facility, DOE contractors should review relevant incidents that have occurred elsewhere in their company, in the DOE complex, or in industry. 51. How should facility sitting and human factors be addressed in a PrHA? Facility siting means the location of covered processes within the plant property. A PrHA 32 DOE-HDBK-1101-2004 team should consider how close a covered process is to workers or high traffic areas when evaluating the potential safety and health impacts of possible releases of HHCs. Possible facility siting issues include the location of vessels containing HHCs and their proximity to other equipment, control rooms, maintenance shops, and administration buildings. Human factors is a broad classification of issues and techniques dealing with the functional relationship between human operators and engineered systems. In a PrHA, human factors could include listing potential human-error causes of accidents; examining the location of and access to critical safety instruments, alarms, and equipment; or reviewing critical procedures used by operators and maintenance personnel. DOE Contractors should examine the specific needs of each covered process to determine an appropriate way to address facility siting, human factors, and other issues in a PrHA. These issues need not be addressed at the same level of detail for all covered processes. 52. The PSM Rule requires that employers promptly address the problems identified in the PrHA in a timely manner, and complete actions as soon as possible. What time frame is intended here? As soon as possible means that DOE contractors must proceed with all due speed, considering the complexity of the recommendation and the difficulty of implementation. OSHA expects employers to resolve PrHA team recommendations promptly; normally within weeks to a few months. DOE contractors should develop a schedule for completion of any corrective actions expected to require more than three months to implement and to document the basis for the extended time needed. 53. What minimum documentation is required in a PrHA report? Because the PSM Rule is primarily a performance-based regulation, no prescriptive documentation requirements have been established for PrHAs. Contractors should include sufficient information to show that the required issues in paragraph (e)(3) of the Rule have been addressed. For example, the report should identify the PrHA team members, the process analyzed, the selected PrHA method used, the manner in which the required PrHA issues were addressed, and the recommendations from the study. Other documentation to support the review depends on the method selected, the process analyzed, and the particular needs of the facility.

54. Can a company prioritize the PrHAs to be performed on a company-wide basis instead of a site-specific basis? Can a large processing complex be divided into several logical systems for the purpose of applying the phase-in provisions for initial PrHAs? PrHAs must be prioritized on a site-by-site basis. When PrHAs are performed on similar processes, DOE contractors may order these analyses to make the best use of their experience. A large, processing complex consisting of several discrete systems (e.g., feed, reaction, purification, storage) or containing several different HHCs may be divided into logical separate processes as long as this division is performed in a technically 33 DOE-HDBK-1101-2004 consistent way. DOE contractors must document their prioritization of processes for PrHA. 55. What rationale must DOE contractors use to determine the priority for conducting PrHAs? Should the rationale include age, history, and extent of employee exposure? The appropriate priority for conducting PrHAs must be determined using all of the criteria identified in this paragraph, i.e., the extent of the process hazards (catastrophic potential), the 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. What is the time requirement for completion of PrHAs for newly covered processes? All initial process hazard analyses must be completed prior to process startup. 57. What does it mean to revalidate a PrHA ? 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. How often are PrHAs performed to satisfy PrHA obligations for the processes analyzed? The PrHA elements must be updated and revalidated at least every five (5) years. 34 DOE-HDBK-1101-2004 2.4 Operating Procedures 29 CFR 1910.119 (f) (1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements. (i) Steps for each operating phase: (A) Initial startup; (B) Normal operations; (C) Temporary operations; (D) Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner. (E) Emergency Operations; (F) Normal shutdown; and, (G) Startup following a turnaround, or after an emergency shutdown. (ii) Operating limits: (A) Consequences of deviation; and (B) Steps required to correct or avoid deviation

(iii) Safety and health considerations: (A) Properties of, and hazards presented by, the chemicals used in the process; (B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment; (C) Control measures to be taken if physical contact or airborne exposure occurs; (D) Quality control for raw materials and control of hazardous chemical inventory levels; and, (E) Any special or unique hazards. (iv) Safety systems and their functions. (2) Operating procedures shall be readily accessible to employees who work in or maintain a process. (3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate. (4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees. Intent Operating procedures are an important tool for achieving safe, consistent, and efficient process operation. Process procedures differ from many procedures because they cover all phases of operations. They must discuss operating limits, the consequences of deviating from these limits, and recovery from deviations. Procedures must address normal, abnormal, and emergency conditions to prepare workers for any event that may reasonably occur. Administrative and special engineering control measures, as well as required monitoring and surveillance equipment must be described. 35 DOE-HDBK-1101-2004 Procedures must be clearly written, with easy-to-follow steps for each operating phase. They should be written at an education level that all process workers can understand. If workers have difficulty understanding instructions in English, contractors should consider providing procedures in a second language understood by the workers, or the workers should be teamed with others who can explain the procedures and provide necessary guidance. Critical or complex procedures may be enhanced with job performance aids, such as flow diagrams, photos, or expanded assembly drawings. A close relationship exists between training and operating procedures. High-quality procedures alone achieve nothing unless the operators are trained in their use. When operating procedures are used for training, the trainer has an opportunity to satisfy procedure review and update requirements by ensuring that the procedure still represents current practice. Procedures should include a graded approach to highlighting dangers, such as the military system of notes, cautions, and warnings. (Notes indicate that care is required. Cautions indicate that incorrect operation may lead to injury or equipment damage. Warnings indicated that incorrect operation may lead to serious injury or major equipment damage.) Safe work practices are also discussed in Section 2.9 because they address nonroutine operations and often require special authorizations. Safe work practices are more generic than procedures and describe a program and an approach for conducting an activity (e.g., confined space entry or lockout/ tagout). Both operating procedures and safe work practices are required for safe process operation.

Seven steps are suggested for developing procedures: Step 1 Determine the tasks involved in operating a process unit, the relationship between the tasks, and the order in which they are to be carried out. Use Job Safety Analyses to identify and discuss hazards associated with each task. Step 2 Analyze each task and reach consensus on how it should be carried out. The analysis should be done by senior operators and supervisors, with input from management and technical staff. Task analysis is often beneficial because it illuminates inconsistencies in the way tasks are performed by different workers on different shifts. Step 3 Write the procedures based in interviews or personal experience, and follow the logic developed in the task analysis. Step 4 Distribute written procedures to operators for comment and discussion. Step 5 Perform a PrHA for the procedures. The PrHA team thoroughly reviews the procedures and generates the safety and health information to be incorporated. Step 6 Ensure that users receive the proper training. Step 7 Ensure that procedures are written and structured so that they can be updated regularly to reflect changes. Note that MOC procedures identify activities that lead to changes in operating procedures. 36 DOE-HDBK-1101-2004 To instill a sense of ownership, each operator may be assigned a portion of procedures to develop, review, and maintenance, even if the first draft of the procedures is written by someone else. This approach is not intended to preclude other workers from writing or amending procedures. Rather, it ensures that someone takes responsibility for their accuracy, timely completion, and current applicability. Corresponding DOE Programs and Requirements DOE O 5480.19 Chg 2, CONDUCT OF OPERATIONS REQUIREMENTS FOR DOE FACILITIES, and DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, contain provisions for written operating procedures. Operating procedures for processes covered by the PSM Rule should be reviewed to ensure that they comply with these requirements. Safe work practices should be reviewed to ensure that they are current. Additional safe work practices may need to be developed if PrHAs identify frequently encountered hazards that are not unique to a given process. Additional DOE guidance is provided in DOE-STD-1029-92 (CH-1), Writer’s Guide for Technical Procedures. Documentation Requirements If operators are to work safely and efficiently, they must understand the reasons for the actions described. Therefore, operating procedures for chemical processes covered by the PSM Rule should describe operator interactions with process units, explaining why actions are to be carried out in the manner described. Generally, procedures should be written at a level of detail such that 1) an experienced operator who is not familiar with a particular process unit could run the unit with minimal supervision or help from other operators, or 2) the least experienced operator released for unsupervised work could run the unit. Operating procedures should be readily available for rapid reference[59]. DOE contractors should develop their own “systems” for confirming that the operating procedures are current and accurate. Contractors must certify annually that procedures for operation of covered processes are current and accurate [Q60]. Minimum Implementation Criteria Operating procedures must be developed to cover all phases of process operations, including the following [Q61].

• Initial startup [Q62]. • Normal operation and/or partial operation. • Temporary operation. • Emergency operations/shutdown. • Normal shutdown. • Start-up following a turnaround or after an emergency shutdown. 37 DOE-HDBK-1101-2004 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. 38 DOE-HDBK-1101-2004 61. Do DOE contractors have to create a written procedure for every job function or task that an operator performs, or only the most important ones?

The PSM Rule specifies the phases of operation for which written procedures are required. However, it does not specify the job tasks necessary within each operating phase. Contractors may determine if job functions and tasks need detailed, step-by-step, written procedures. For example, in some cases detailed procedures for drawing laboratory samples from processes may be needed to train employees to safely conduct sampling tasks. In other cases, sampling tasks may not present any hazard to a worker, and a detailed written procedure would not be necessary. 62. If an existing process has already undergone initial startup (e.g., after an emergency shutdown, or turnaround), must a written procedure for initial startup be developed in addition to procedures for other types of startups? DOE contractors should have operating procedures for every type of startup expected during the life of a process. Many contractors will use the initial startup procedure for startups following major turnarounds or long outages. If a particular phase of operation specified in the PSM Rule is not relevant to a process, contractors should document this fact. 63. Does control measures to be taken if physical contact or airborne exposure occurs refer to first aid, or industrial hygiene services? The term control measures refers to first aid procedures or emergency medical attention, which should be consistent with the information on material safety data sheets. 39 DOE-HDBK-1101-2004 2.5 Training 29 CFR 1910.119 (g) (1) Initial training. (i) Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks. (ii) In lieu of initial training for those employees already involved in operating a process on (Insert the effective date of the standard), an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures. (2) Refresher training. Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training. (3) Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. Intent DOE contractors must train all employees involved in operating and maintaining chemical processes covered by the PSM Rule, including supervisors and managers, and temporary or intermittent workers [Q66]. Contractors must decide what level of training is needed and how that training is to be provided (e.g., classroom, hands on, on the job, equipment familiarization). Training must ensure competency, and contractors must document the means used to employee understanding (e.g., tests, demonstration of skills, etc.). Training must result in employees understanding: • chemical hazards and the controls;

• proper procedures; • safe operating limits and how to avoid unsafe conditions; • how to respond to upset and emergency conditions; and • opportunities available for employees to contribute to process safety improvements. Training programs should have the following elements: • Written training plans and schedules. • Qualified trainers. • Training materials on the process tasks. • Methods to ensure that competencies are developed (e.g., testing appropriate to the complexity of the operations and the hazards involved). 40 DOE-HDBK-1101-2004 • Periodic review of operations/activities to ensure that operators follow procedures and competencies are maintained. Initial training is required before assigning an employee to work at a covered process. Refresher training is required at least every 3 years, or more frequently based on complexity of the operations and consultation with employees [64]. DOE contractors are encouraged to obtain worker input to identify needs, assist in development, and review content of initial and refresher training. Corresponding DOE Programs and Requirements All DOE sites have safety training programs, including Hazard Communication training as required by OSHA (29 CFR 1910.1200), and other generic and job-specific safety training. Each site has a system for documenting training. Thus, the training infrastructure is in place to support required PSM training. Existing training must be examined to ensure that all information required by the PSM Rule is included. DOE O 360.1B, FEDERAL EMPLOYEE TRAINING, and DOE O 440.1A, WORKER PROTECTION MANAGEMENT FOR DOE FEDERAL AND CONTRACTOR EMPLOYEES, provide general training requirements. DOE 5480.20A Chg 1, PERSONNEL SELECTION, QUALIFICATION, AND TRAINING REQUIRMENTS FOR DOE NUCLEAR FACILITIES, establishes selection, qualification, training, and staffing requirements for personnel involved in the operation, maintenance, and technical support of DOE reactor and non-reactor nuclear facilities. Additional DOE guidance is available in DOE- HDBK-1205-97, Guide to Good Practices for the Design, Development and Implementation of Examinations. Documentation Requirements Training records must be maintained which identify the process operator, the date of training, and the method used to verify successful completion and understanding of the training. Although not required, checklists covering the required training and testing are often useful tools to ensure that training requirements are completed prior to job assignment. Minimum Implementation Criteria Initial and refresher training (every three years or more frequently as needed are required. Initial training for new process operators or operators new to a process must emphasize: • safe work practices, including startup, normal operations, and temporary operations procedures; • hazardous chemicals and specific safety and health hazards and precautions for preventing exposure; • emergency procedures, including shutdown and startup procedures; • Standard Operating Procedures (SOPs) and Job Hazard Analyses (JHAs); • accidents and near misses; 41 DOE-HDBK-1101-2004 • operating limits, the consequences of deviations, and the steps required to avoid deviations; • equipment and process parameters, such as pressure, flow, and temperature.

Review of initial training elements is needed because process practices change over time and may not reflect desired procedures or behaviors. Thus, management must emphasize the importance of procedures and behaviors during training reviews [65]. The following elements should be emphasized in refresher training. • Current operating procedures of the process. • Impacts of recent or planned process and equipment changes. • Changes in equipment and process parameters such as pressure, flow, and temperature. • Process accidents, incidents, or near misses. Written tests provide assurance that training is effective, although the PSM Rule does not require that formal written tests be used. DOE contractors may choose to have operating managers or supervisors from covered processes review the training and experience level of employees already involved in operating the processes [Q66, Q67, Q68]. Questions 64. Which employees must receive training (e.g., operators, engineers, shift foremen, janitors, plant managers)? DOE contractors should develop an appropriate level of initial and refresher training for every worker involved in operating a covered process, including operators and other employees expected to carry out duties specified in the operating procedures. In addition, because the preamble to the PSM Rule specifically states that “this paragraph [operating procedures] is not intended to be limited to equipment operators,” supervisors and managers who provide interpretation and guidance concerning operating procedures should receive appropriate training. Persons not involved in the actual operation of a covered process (e.g., janitors, plant managers) are not required to have process-specific training as defined by the PSM Rule. 65. What topics must be covered in refresher training? Is there a minimum amount of time DOE contractors must spend on refresher training? How often should refresher training be conducted? Must contractors document that employees understand refresher training? Contractors should develop topics based on the operating procedures appropriate for each job. Because of the performance-based nature of the PSM Rule, no minimum number of hours or frequency for refresher training is specified. The frequency of refresher training should be determined by consulting with employees involved in operating a process, but it must be provided at least every 3 years. Although not specifically stated in the PSM 42 DOE-HDBK-1101-2004 Rule, DOE contractors should apply the same documentation and verification requirements for refresher training as for initial training. 66. What criteria must DOE contractors follow and what documentation must DOE contractors have to grandfather the initial training of existing employees? DOE contractors should decide what criteria to use to certify that existing employees have “the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures.” Contractors may choose to have operating managers or supervisors for covered processes review the training and experience level of employees already involved in operating the processes. 67. What criteria must DOE contractors use to determine whether employees understand their training? What documentation is needed to provide evidence of this understanding?

DOE contractors should develop their own criteria appropriate for job functions and types of training delivered (e.g., classroom, on-the-job). Documentation should be appropriate to the training provided. For example, test scores may be adequate to demonstrate understanding of classroom training. In-the-field skill demonstrations or on-the-job quizzes may also be appropriate. In every case, the means used to verify that the employee understands the training must be documented. 68. The PSM Rule requires that DOE contractors make sure that operators understand the training provided to them under this section. Is some method of testing required? Some positive means must be taken by DOE contractors to ensure that employees understand their training and are capable of adhering to current operating procedures. Assurance could be gained through the administration of written tests, although the PSM Rule does not require that formal written tests be used. Other means of ascertaining comprehension, such as on-the-job demonstrations, are acceptable so long as they are adequately documented. 43 29 CFR 1910.119 (h) DOE-HDBK-1101-2004 2.6 Subcontractor Safety Where OSHA speaks of employers, this handbook uses DOE contractors. The term DOE contractor refers to Management and Operation (M&O), Environmental Remediation Management Contractors (ERMC), and other DOE prime contractors. Where OSHA speaks of contractors, this handbook uses subcontractors. This section applies to such DOE subtier contractors, performing maintenance, repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to incidental subcontractors such as vendors, janitorial workers, or delivery services. 29 CFR 1910.119 (h) (1) Application. This paragraph applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services. (2) Employer responsibilities. (i) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer’s safety performance and programs. (ii) The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process. (iii) The employer shall explain to contract employers the applicable provisions of the emergency action plan required by paragraph (n) of this section. (iv) The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in covered process areas. (v) The employer shall periodically evaluate the performance of contract employers in fulfilling their obligations as specified in paragraph (h)(3). (vi) The employer shall maintain a contract employee injury and illness log related to the contractor’s work in process areas. (3) Contract employer responsibilities. (i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job. (ii) The contract employer shall assure that each contract employee is instructed in the known potential fire,

explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan. (iii) The contract employer shall document that each contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training. (iv) The contract employer shall assure that each contract employee follows the safety Rules of the facility including the safe work practices required by paragraph (f)(4) of this section. (v) The contract employer shall advise the employer of any unique hazards presented by the contract employer’s work, or of any hazards found by the contract employer’s work. 44 DOE-HDBK-1101-2004 Intent The objective of the subcontractor safety element is to ensure that levels of safety are not compromised by subcontractor operations and that subcontractor employees are an integral part of the PSM program. (A sample subcontractor safety program is provided at the end of this section.) Prior to hiring such subcontractors, DOE contractors must screen their safety programs and performance to ensure that they have the knowledge, skills, and certifications to safely complete the work [Q69]. The subcontractor safety element includes requirements for both DOE contractors and their subcontractors, as described below. Corresponding DOE Programs and Requirements Most DOE contractors are required to describe applicable workplace hazards and to monitor the safety of subcontractor operations as part of traditional safety programs. These programs are reexamined periodically to ensure continued control under conduct of operations and maintenance management requirements. Similarly, such programs must be examined for consistency with the requirements of the PSM subcontractor safety element. DOE has program oversight responsibility for DOE contractors. However, the principle focus of this PSM element is on DOE contractors who have operational control of covered processes and their subcontractors whose work might affect these process units. Documentation Requirements DOE contractors may use a variety of methods to ensure that subcontractors comply with obligations under the PSM Rule, including pre-contract evaluation of safety programs, periodic inspections of a work site, reviews of subcontractor training programs and records, and inspection of subcontractor incident reports. These methods can be used to obtain a sampling of contractor activity. The results of physical and record-keeping audits can be summarized and retained in a subcontractor performance file [Q70]. DOE contractors are required to maintain a log of subcontractor injuries and illnesses (OSHA 200 Form) for operations in the vicinity of processes covered by the PSM Rule. Subcontractors are required to document worker training. Minimum Implementation Criteria DOE contractors must: • obtain and evaluate information about subcontractors safety and performance including safety manuals, current injury and illness incidence rates, and the past years OSHA 200 Log; • before work begins, inform subcontractors of the potential fire, explosion, and toxic release hazards related to the subcontractors work and describe the process; • provide for subcontractor employee access to PrHAs and PSI for the processes where they are working [Q71];

• explain the applicable provisions of the emergency action plan to subcontractors; 45 DOE-HDBK-1101-2004 • develop and implement safe work practices to control the entrance, presence, and exit of subcontractors; • conduct periodic evaluations of subcontractor worker performance and training and ensure compliance with applicable PSM and other safety requirements; • verify that each subcontractor worker is trained in the work necessary to perform the job safely [72]; • maintain an employee injury and illness log related to the subcontractors work in process areas covered by the PSM Rule [Q73]; • establish a work authorization or permit system to control access to process areas and ensure that workers are aware of subcontractor operations that may have an impact on covered processes; • provide relevant information from the process and site emergency action plans to subcontractors so that their employees know what to do in an emergency [Q71]. Subcontractors must: • train each worker in the potential fire, explosion, or toxic release hazards related to the job and the process, and the applicable provisions of the emergency action plan [Q71]; • document worker training required by the PSM Rule with records that identify the employee and date of training, and include a means to verify successful completion • ensure that each of its workers follows the safety rules of the facility, including the safe work practices; • advise DOE contractors of any unique hazards presented by their work, or of any hazards found in the course of their work. Questions 69. Must contractors apply all of the PSM Rule contractor requirements to a subcontractor already working on or near a covered process? Yes. DOE contractors should consider evaluating their programs and performance as a way of ensuring that the subcontractor is able to comply with the facility’s safe work practices. However, the PSM Rule does not require that DOE contractors subject existing subcontractors to the pre-contract screening designed for selection of new subcontractors. 70. What is acceptable documentation for ensuring that a subcontractor complies with its obligations under the PSM Rule? DOE contractors may use a variety of methods to ensure that subcontractors comply with obligations under the PSM Rule, including periodic inspections of a work sites, reviews of subcontractor training programs and records, and inspection of subcontractor incident reports. Each method can be used to obtain a sampling of subcontractor activity. The results of these physical or record-keeping audits can be summarized and retained in a subcontractor performance file. 46 DOE-HDBK-1101-2004 71. Who is responsible for training subcontractor employees to do their job safely? Who is responsible for providing site-specific safety orientation? Subcontractors are responsible for training their own employees. DOE contractors are responsible for providing their subcontractors with sufficient hazard and process information to enable them to conduct appropriate training. DOE contractors are also responsible for ensuring that this training has been performed. Further, DOE contractors are responsible for providing sufficient emergency action plan information to subcontractors so that their employees know what to do in an emergency. In some cases, it may be more efficient for DOE contractors to perform safety orientations and to familiarize subcontractor employees with emergency action plans. In these cases, the training responsibilities of the two parties should be clearly defined and understood.

72. When a subcontractor is hired to perform a job for which a DOE contractor has no expertise, how can the DOE contractor be expected to ensure that the subcontract employees are trained to do their job safely? A DOE contractor must establish safe work practices for the facility and is expected to require subcontractors to follow these practices. Although a DOE contractor is not expected to know all requirements for a specific work practice associated with a special skill or craft for which the subcontractor was hired (e.g., proper handling of hazardous waste generated as a result of a unique maintenance activity), the DOE contractor is required to evaluate and audit the subcontractor’s own safety programs and practices. 73. Is a subcontractor injury/illness log required during the construction of a covered process? If a new process is being built in an area totally removed from any other covered process, and if no HHC has been introduced, the subcontractor injury/illness log provision does not apply. However, if an existing process has been made chemical-free for construction purposes, the subcontractor element of the PSM Rule still applies, due to the potential presence of residual chemicals. 47 Exhibit 2.6.1 DOE-HDBK-1101-2004 Sample Subcontractor Safety Program (This sample Subcontractor Safety Program uses mandatory language that a DOE contractor might use in such a document. It is not intended to imply that this sample program is mandatory for DOE use. Italicized references to the DOE contractor are used in place of a specific contractor.) INTRODUCTION I. General A. Introduction Subcontractors play a vital role in the day-to-day operation of DOE-owned facilities. They perform a variety of tasks that range from general maintenance to specialty work. In providing these services, subcontractor employees may work in and around processes that involve highly hazardous chemicals. Therefore, it is important that these subcontractors are knowledgeable in the dangers posed by these chemicals. B. Scope and Objectives This program applies to those subcontractors that are involved in safety-sensitive work, such as maintenance, repair, turnaround, or major renovation. This guide includes the principles, practices, and requirements of OSHA's PSM Rule. This program also addresses the screening process used to select subcontractors. It defines the responsibilities of both the DOE contractor's management and the subcontractor in ensuring that all employees accomplish their work safely. II. Subcontractor Responsibility A. Pre-Selection 1. Subcontractor Qualifications The DOE contractor shall do a preliminary check on subcontractors for the type of work that they will perform at the Government Owned Contractor Operated (GOCO) facility. This check shall involve asking the potential subcontractor to submit the information contained in the Subcontractor’s Safety Questionnaire enclosed as Exhibit 2.6.2. DOE contractors are encouraged to share qualified sources. 2. Approved Subcontractor List The DOE contractor shall develop a list of approved subcontractors from the data collected in (1) above. 3. Audit of List The Approved List should be audited yearly to ensure that subcontractors continue to meet this guide’s requirements. 48 DOE-HDBK-1101-2004 Exhibit 2.6.1 4. Validation Data submitted should be revalidated to ensure that it applies to the local subcontractor and not to its parent company or an affiliate. B. Pre-Bid

The DOE contractor shall inform subcontractors of the facility’s safety requirements by clearly outlining safety performance requirements in its bid package, which will be used as part of the selection process. The DOE contractor shall request specific safety information from the subcontractor to compare with qualification criteria to establish contractor responsibility. The subcontractor should be advised of the qualification criteria and that the lowest bid might not be selected. 1. Subcontractor Suitability to Bid Once the scope of work has been defined, the DOE contractor will request that subcontractors selected to bid submit all safety management program information necessary to establish contractor suitability. 2. GOCO Facility Safety and Health Qualification Criteria The DOE contractor shall clearly outline safety and health requirements in the bid package. The items contained in the Subcontractor’s Safety Questionnaire (Exhibit 2.6.2) should be included, along with any site specific safety and health rules that might apply. These requirements shall be consistent with the requirements the DOE contractor has for its own employees. 3. Contract Safety Language Standard safety language (“the subcontractor must comply with all federal, state, and local safety laws and regulations”) shall be included in contracts. Also, safety and health requirements specific to the GOCO facility and the work being performed shall be included in the contract as a separate addendum. 4. Pre-bid Meeting The DOE contractor shall hold a pre-bid meeting to discuss facility safety and health requirements. Subcontractors shall be provided copies of any applicable facility safety and health policies and procedures. This meeting shall also establish who provides the required safety and health equipment and training, and shall define subcontractor documentation requirements. C. Selecting Subcontractors 1. Considerations The DOE contractor shall review each subcontractor's Safety Questionnaire, along with the requested material, for thoroughness and ability to meet or exceed the facility’s minimum safety and health qualification criteria. The subcontractor’s ability to safely perform the specified work should be a 49 DOE-HDBK-1101-2004 significant factor, along with cost, quality and time. The reasoning used to select the subcontractor must be documented. 2. Safety and Health Rating System A subcontractor safety and health rating system should be developed to help in evaluating the subcontractor's ability to safely perform the specified work. D. Pre-Job Safety and Health Meeting 1. Discussion of Specific Safety and Health Requirements GOCO facility management shall specifically discuss safety, unusual hazards, training, documentation, and permit requirements with the subcontractor’s site management personnel, who will be directly responsible for supervising the contracted work. 2. Verifying Training Requirements The DOE contractor management shall review subcontractor certifications for required training based on criteria set forth in the Pre-bid section. Safety and health training for subcontractor employees can be divided into three components. • Basic job skills training: the skills required to perform a specific task. • Basic job safety and health training: the skills necessary to safely perform the task no matter where it may be performed. • Plant-specific safety and health training: the skills necessary to safely perform a task at a specific plant site.

The first two components are the responsibility of the subcontractor and the third is the responsibility of the DOE contractor. To fulfill the obligations of the first two training components, the subcontractor shall be requested to define the training needed to satisfy these components, provide the training, and certify that the training has occurred, enabling their respective workers to safely perform their assigned duties. The subcontractor will not be able to start on the project until these training requirements are met. Also, arrangements will be made with the subcontractor to schedule the safety orientation that covers plant-specific safety and health training. E. Subcontractor Safety Orientation Before work begins, all subcontractor personnel, including supervisors and managers, shall receive the GOCO facility’s safety and health orientation. Where this training is not provided by the DOE contractor, management will ensure that it is conducted and covers the same site-specific safety and health material that GOCO facility employees receive at their new hire orientation. Training content and attendance must be documented. 50 DOE-HDBK-1101-2004 F. On the Job Control 1. Review Subcontractor Safety Performance The DOE contractor shall designate a representative (site contact) for each contract issued to subcontractors performing work onsite. This site contact will have the authority to enforce the provisions set forth in the contract. The site contact shall be required to monitor and make regular inspections of the subcontractor’s activities as follows. • Audit work to verify that all safety and health related clauses in the contract are being followed. • Conduct regular safety and health review meetings with the subcontractor’s site manager that include review of incidents, status of documented inspection items needing correction, status of concerns raised during the safety meeting, and any other concerns the contact administrator has about the subcontractor’s safety and health performance. • Counsel and stop work, if necessary, if the subcontractor is working in an unsafe manner. If work is stopped, the subcontractor will not be allowed to return to work until the unsafe practice is corrected. The site contact will notify the subcontractor, in writing, of the unsafe practice and will require the subcontractor to submit a report as to why this unsafe practice was allowed to occur and what steps have been taken to prevent recurrence. Delays resulting from these work stoppages may be considered a breach of the subcontractor’s contractual obligations. 2. Maintain Safety Statistics for Subcontractor Injuries Each subcontractor shall submit monthly safety reports with monthly and cumulative accident statistics. 3. Accident Report Each subcontractor shall be required to submit written reports of all events resulting in or having the potential for injury, damage or loss to the GOCO facility’s safety department with immediate notification to the site contact responsible for the subcontractor’s contract. If the incident involved an injury requiring medical treatment or has the potential to cause a serious incident, the site contact and the GOCO facility’s management will meet with the subcontractor to discuss the incident and means to prevent recurrence. 4. Monitor Training The GOCO facility shall establish a control point to monitor subcontractor personnel entering the facility to ensure that no new employees are brought onto the site without the required training.

51 DOE-HDBK-1101-2004 5. Specific Job Instruction For hazardous operations, the site contact and the subcontractor shall develop a work plan (i.e., job safety analysis, safe job procedure, etc.) and go over it with all personnel doing the hazardous work. Work shall not start until everyone understands how to accomplish the work safely. G. Performance Evaluation 1. Performance Reports Upon completion of the project, the site contact shall submit a performance report on the subcontractor’s completed project, discussing safety, work quality, schedule adherence and budget adherence. A draft of this report should be circulated to appropriate GOCO facility personnel for comment before the final review with the subcontractor. 2. Post Job Performance Review The final review with the subcontractor should include the site contact, the safety supervisor, the GOCO facility contract committee, and other appropriate GOCO facility management. At this review meeting, the subcontractor shall be given an overall assessment of work performance and will be told whether the subcontractor will be permitted to bid on any future projects at the facility. III. Subcontractor Responsibilities A. Written Safety Program Subcontractors shall have a written safety program, which shall be reviewed by the GOCO facility. B. Compliance with GOCO Facility Safety Requirements The subcontractor shall ensure that all its employees understand and follow the GOCO facility’s safety and health requirements. C. Safety Inspections The subcontractor shall conduct monthly safety and health inspections that will be documented with a system to track recommendations to a final resolution. Copies of the documented inspections and the resolution of the recommendations will be forwarded to the subcontractor’s site contact and the GOCO facility’s safety department. D. Accident Investigation Reporting & Record Keeping While working at the GOCO facility, the subcontractor will report all accidents that result in an injury or illness to the subcontractor’s site contact and the GOCO facility’s safety department. An investigation shall be initiated within 48 hours after occurrence. The subcontractor shall have a system in place to track identified corrective recommendations to final resolution. A copy of the investigative report with documentation showing final resolution of the accident’s corrective recommendations will be forwarded to the DOE contractor's site contact and safety department. The subcontractor shall keep site injury statistics that include the total number of man-hours that the subcontractor has worked at 52 DOE-HDBK-1101-2004 the GOCO facility, the number of recordable injuries, the recordable incident rate, the lost work day case incident rate, the severity rate and the number of first aid cases. These statistics shall be kept on a monthly and a cumulative basis. The subcontractor should be able to obtain much of this information from the OSHA 200 Log. E. Job Planning To ensure safety and health during hazardous operations, the site contact and the subcontractor shall develop a work plan (i.e. job safety analysis, safe job procedure, etc.) and review it with all personnel involved. Work will not commence until everyone understands what is required to accomplish this work safely. F. Safety and Health Training 1. Basic Job Skills and Safety Training

The subcontractor shall providing training to ensure its employees are competent and skilled in the trade or craft that they will be practicing at facilities. They shall also provide training in the basic safety skills necessary. Subcontractors shall be required to submit written documentation that defines their training systems, certifies training has occurred, and that their workers are competent to safely perform their assigned duties. 2. Plant Specific Safety Training The subcontractor shall ensure that all its employees have attended the GOCO facility’s safety and health orientation. They will also agree not to bring any employee into the DOE contractor's site until that employee has received this orientation. 3. Safety Meetings The subcontractor shall hold routine safety meetings, monthly at a minimum. These meetings should conform to the following basic guidelines. • Subject material should be preplanned. • Subject should be job related and timely. • Meetings should be conducted by a competent person • Provisions should be made for employee feedback. • Meeting content and attendance should be documented. • Copies of these meetings should be forwarded to the GOCO facility’s site contact and safety department. 53 DOE-HDBK-1101-2004 Exhibit 2.6.2 Sample Subcontractor Safety Questionnaire Company: __________________________________________ Date: _____________________ I. Your Firm's Safety Performance and Program A. Workers Compensation Insurance - Experience Modification Rate (EMR) 1. Please obtain from your insurance agent (or state fund, if applicable) your interstate EMR for the last three rating periods and complete the following. Policy Year Modification Rate Most Recent Policy Year ___________ ______________ 1 year previously ___________ ______________ 2 years previously ___________ ______________ Are the above rates interstate or intrastate? ___________________ If intrastate, which state? ________________ If your EMR is exactly 1.0 for any policy year, is it because your firm is (was) too new or too small to have an EMR calculated? [ ] Yes [ ] No Is your firm self-insured for Workers Compensation claims? [ ] Yes [ ] No 2. We require back-up for the above information. Which of the following methods would be acceptable: • Furnish a letter from your insurance agent, insurance carrier, or state fund (on their letterhead) verifying the EMR data listed above, or • Furnish a photostat of the last 3 years, Experience Rating Calculation Sheets, which your insurance carrier should forward to you annually; or • Furnish a photostat of the page of your last 3 year’s insurance policies that shows the modification rate and the coverage period; or • If you’re in a state fund state, such as Ohio or West Virginia, furnish a photostat of the state’s last 3 years' annual statement page that shows the modification rate and the coverage period: B. OSHA Recordable Incidents 1. Furnish a copy of your firm’s OSHA 200 Log and total man-hours for each year from the last 3 years. Indicate which injuries occurred at the GOCO facility. 54 ___________________ _______________ _______________ _______________ DOE-HDBK-1101-2004 Exhibit 2.6.2 2. Some firms are not required to complete OSHA 200 Log, because they have too few employees. (a) If you haven’t completed the OSHA Log, is it because your firm has too few employees? [ ] Yes [ ] No If you answer “NO,” please explain.

(b) If your company does not have to keep an OSHA 200 Log, provide a yearly list for the past 3 years of injuries resulting in lost time and a list of injuries not resulting lost time along with total man-hours worked for each year. 3. Total employee hours worked last year at the GOCO facility? _______________ 4. Your OSHA Recordable Incidence Rate1 for last 3 years? Last Year __________ 1 Year Previous __________ 2 Years Previous __________ 5. Your Lost Workday Incidence Rate2 for last 3 years? Last Year ___________ 1 Year Previous ___________ 2 Years Previous ___________ C. Industry Comparison Information 1. What North American Industry Classification System (NAICS) Code does your company work under? 2. What is the OSHA Recordable Incidence Rate (most recent year) for your NAICS? 3. What is the Lost Workday Incidence Rate (most recent year) for your NAICS? 4. If your OSHA Recordable Incidence Rate and/or Lost Workday Incidence Rate is greater than your NAICS code rate, attach a brief explanation and describe the action plan that your company is using to improve your rates. D. Safety Policy and Organization 1. Do you have a written statement of your safety policy? (Please provide a copy.) 2. How is the safety policy communicated to employees? 1 OSHA Recordable Incidence Rate = #Recordable Injuries X 200,000 / Manhours 2 Lost Workday Incidence Rate = #Lost Workday Injuries X 2,000,000 / Manhours 55 DOE-HDBK-1101-2004 Exhibit 2.6.2 3. Do you have a safety organization? (Please provide an organization chart and description of responsibilities.) 4. Who is the most senior person for coordinating safety matters, and what is his/her experience? 5. Is management accountable for safety performance? If so, state how this is practiced. E. Procedures 1. Do you have a safety manual? (Provide current copy). 2. Do you have written safe working practices and safety policies, such as those covering hazard communications, use of scaffolding, etc. (Provide a copy). F. Safety Training 1. What safety training is given to your employees and up to what level of management is it given? (Provide details and examples) 2. Have the personnel who will undertake specific work received formal training in safe working practices and in the use of protective equipment relating to the potential hazards of the work? (Provide details.) 3. What formal safety qualifications does your staff have? (Describe) G. Accident Investigation 1. Do you have a procedure for the investigation, reporting, and follow-up of accidents, near misses, and occupational injuries? 2. How are the results of accident investigations communicated to your employees? (Please give examples.) H. Safety Awareness 1. Do you organize in-house safety meetings? (Describe the frequency, attendance and topics). 2. Do you have an established system for communicating safety matters to workers? 3. Do you conduct safety inspections on your own operations? If so, how are unsafe acts and/or conditions resolved? I. Subcontractors 1. What safety requirements do you specify for your subcontractors? 2. Do you have procedures for the control of the safety performance of a subcontractor? (If so, please give details). 56 ________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ _____

DOE-HDBK-1101-2004 Exhibit 2.6.3 Sample Subcontractor Safety Program Evaluation and Criteria Subcontractor: Address: Point of Contact_____________________________ Phone Number _________________ I. Safety Program Evaluation Rating Circle the number which best represents this evaluations based on the criteria for rating purposes attached. A B C D Comment Safety Program 1. Policy Statement 0 3 7 10 2. Safety Manual 0 3 7 10 3. Emergency Response Procedures 0 3 7 10 4. Basic Safety Rules 0 3 7 10 5. Accident Reporting Procedure 0 3 7 10 6. Employee Orientation Program 0 3 7 10 7. Safety Meeting Program 0 3 7 10 8. Safety Training Program 0 3 7 10 9. Safety Inspection Program 0 3 7 10 10. Professional Safety Support 0 3 7 10 11. Alcohol/Drug Control Policy 0 3 7 10 Total Rating __ + __ + __ + __x.60 = Rating 57 DOE-HDBK-1101-2004 Exhibit 2.6.3 A B C D Comment Safety Performance 1. Latest year injury frequency rate compared to average of previous 3 years. 0 7 14 20 2. Latest year injury severity rate compared to average of previous 3 years. 0 7 14 20 3. The 3-year cumulative injury frequency rate compared to industry 3-year average. 0 10 20 30 4. The 3-year cumulative injury severity rate compared to industry 3-year average. 0 10 20 30 Total Rating __ + __ + __ + ___ x.60=Rating Summary The numerical values below are the weighted ratings calculated above. The total represents the overall score for the subcontractor. A. SAFETY PROGRAM __________ B. EXPERIENCE FACTORS __________ TOTAL RATING __________% Evaluated by: ____________________________ _________________________ ___________ Title Date 58 DOE-HDBK-1101-2004 Exhibit 2.6.3 II Safety Program Evaluation Criteria Safety Program Documentation A B 1. Policy Statement No written Safety Policy A policy statement exists in a widely distributed document 2. Safety Manual None written A few basic safety procedures exist. 3. Emergency Response Procedures None written Basic procedures only. 4. Basic Safety Rules No written rules Safety rules are in memo/document form. C Safety Policy establishes responsibility for safety, but not widely distributed to supervisors. Subcontractor has written procedures to cover all applicable DOE contractor safety precautions. Emergency procedures written for major scenarios, e.g. fire/ explosion; release of toxic or flammable materials; and medical emergencies. No requirements established for drill frequencies. Safety rules are incorporated in Safety Manual, but not in a D Policy clearly establishes responsibility and accountability and is distributed to all supervisors. Subcontractor has written procedures to cover all applicable DOE contractor program requirements. Emergency procedures for all major scenarios, e.g. fire/explosion; release of toxic or flammable materials; and medical emergencies. Emergency Procedures distributed to all staff. Drill frequency is established and followed. Safety rules exist in handbook form distributed to all 59 DOE-HDBK-1101-2004 A B C D format which is distributed to all employees. employees. Disciplinary actions are established for infractions of safety rules. 5. Accident reporting procedure No Procedure exists Written procedures requiring basic reporting of personal injuries only Written procedure requiring reports on all accidents /incidents. Procedure indicates that accident reports must be provided to supervisor and that investigation of accidents and incidents is required to determine and

6. New Employee Orientation Program correct root cause. 7. No formal program Safety Meeting Program Verbal instructions on company procedures only. Orientation booklet provided for new employee, but no on the job orientation by the supervisor. Employee handbook provided and supervisor describes and demonstrates new employee’s job. Safe work practices and emergency duties are also discussed. Follow up observation of new employee at work is included. None Periodic safety meetings for special operations only. Safety meetings performed on a regularly scheduled basis by the supervisor or safety representative. In addition to C, employees are assigned topics to discus on a regular basis. 8. Safety Training Program 60 DOE-HDBK-1101-2004 A B C D None Safety materials distributing for reading Has generic safety and health classes and pre­ job briefings. Job-specific training with C and training is documented. 9. Safety Inspection Program None Occasional safety inspections by untrained workers Periodic inspections by trained individual documented. Formal safety inspection/resolution program with monthly inspections plus C. 10. Professional Safety Support No professional Offsite support from corporate office. Onsite support lacks professional status or is limited. Experienced onsite professional safety support 11 Alcohol/Drug Control Policy A policy exists The policy is enforced and B. Policy provides treatment/counseling for those seeking it and C. Experience Factors A B C D 1. Latest year injury frequency rate compared to average of subcontractor’s three preceding years. Subcontractor Rate is 26% to 75% Rate is within +/- 25% Rate is more than 25% below supplied insufficient above the average of the of the average of the the average of the information to establish subcontractor’s three subcontractor’s three subcontractor’s three rate, or rate is more proceeding years. preceding years. proceeding years. than 75% higher than the average of the subcontractor’s three proceeding years 2. Latest year injury severity rate compared to average of subcontractor’s three proceeding years. Subcontractor Rate is 26% to 75% Rate is within +/-25% of the Rate is more than 25% below supplied above the average of the average of the the average of the 61 4 DOE-HDBK-1101-2004 insufficient subcontractor’s three subcontractor’s three subcontractor’s three information to proceeding years. preceding years. preceding years. establish rate, or rate is more than 75 % higher than the average of the subcontractors three proceeding years. 3. Three year cumulative injury frequency rate comparison to comparable industry three year cumulative rate. Subcontractor Rate is more than one but Rate is within +/- one Rate is more than one supplied less than two standard standard deviation of the standard deviation below the insufficient deviations above the industry norm. norm information to industry norm. establish rate, or rate is more than two standard deviations higher then industry norm. Three year cumulative severity rate comparison to comparable industry three year cumulative rate. Subcontractor Rate is more than one but Rate is within +/- one Rate is more than one supplied less than two standard standard deviation of the standard deviation below the insufficient deviations above the industry norm. norm. information to industry norm. establish a cumulative injury severity rate, or rate is more than two standard deviations higher than industry norm.

62 DOE-HDBK-1101-2004 2.7 Pre-Startup Safety Review 29 CFR 1910.119 (i) (1) The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. (2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process (i) Construction and equipment are in accordance with design specifications; (ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate; (iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, paragraph (l). (iv) Training of each employee involved in operating a process has been completed. Intent The purpose of PSRs is to ensure the following. • New or modified facilities and equipment are built and installed in accordance with design requirements. • All process procedures and related process operator training are adequate and completed prior to the introduction of hazardous materials into the process. • Adequate safety reviews are conducted • All PrHA safety recommendations are complete prior to startup. PSRs are important in MOC procedures after a process has been modified [Q74] or shut down for process safety-related reasons. Corresponding DOE Programs and Requirements DOE readiness reviews serve many of the same functions as PSRs. PSRs completed for processes covered by the PSM Rule support DOE readiness review requirements. Operational readiness reviews are currently required for start and restart of nuclear facilities under DOE O 425.1C, STARTUP AND RESTART OF NUCLEAR FACILITIES. There is a general requirement for readiness reviews for new facilities under DOE O 430.1B, REAL PROPERTY ASSET MANAGEMENT. Documentation Requirements PSR documentation includes a checklist of items reviewed and the resulting action plan. (A sample PSR checklist is provided at the end of this section.) DOE contractors should use a graded approach to conducting PSRs. For simple processes, it may be adequate to complete a form with appropriate authorization blocks indicating that the covered process is ready for 63 DOE-HDBK-1101-2004 startup. Information should be documented by checklists and formal readiness review plans for initial startups or following a safety related shut-down. This documentation, with the appropriate approvals, must be maintained on file to indicate the equipment was constructed according to the design specifications and was properly installed and tested. Other documents, such as training records and procedure sign-offs, must also be available. Minimum Implementation Criteria A qualified team should be assembled to conduct each PSR. This team, at a minimum, should include individuals with design and process safety expertise. The team must conduct a physical examination of the plant, process, or equipment that is new or modified, or that has been shutdown for safety reasons. The physical examination is to verify that the plant or process was built according to design, and that all necessary safety features are included and functioning. This examination must include interviews with key personnel and reviews of documentation, such as specifications and drawings, to verify that the design criteria are met.

A system should be in place to track, address, and close out issues identified by incident investigations, audits, PrHAs, or the PSR. A PSR tracking system can be encompassed within existing internal self-assessment and corrective action tracking programs within DOE. The tracking system should be used to ensure that the process is not operated with unresolved issues that significantly degrade the safety of operations. The level or depth of a PSR should be consistent with the level of hazard of the process or the reason for shutdown. A written action plan must be developed for each PSR. As a minimum, all plans must include the scope of the PSR, names of the PSR team members and their qualifications, the PSR objectives, the action items, and the individuals responsible for the action items. For new facilities, a PrHA is performed and recommendations are resolved or implemented prior to startup. For existing processes, MOC items, such as training and procedures, are addressed. Questions 74. How should DOE contractors interpret the phrase when the modification is significant enough to require a change in PSI? Must the same PSR procedure be used for all significant changes? Contractors should define the types of startups they expect to experience following maintenance or construction on covered processes. They should then design appropriate PSR approaches for each situation using a graded approach. Not all PSRs must be completed using the same number or types of people, or using the same review method. PSRs for major or complex new processes are expected to be greater in scope, take longer, and involve more resources than the startup of simple processes or a restart after relatively minor process modifications. 64 ______________________________________________________________________________ _____________________________________________________________________________ ______________________________________________________________________________ DOE-HDBK-1101-2004 Exhibit 2.7 Sample Prestart Safety Review Date: ______________ PSR Team Leader: ________________________________________ Facility / Process / Equipment: _______________________________________ _______________________________________ Type of Startup: New Construction ______ Process Modification ______ List of Associated PSR Checklist Materials (and location if not attached to this form): PSR Completion Summary: The following issues have been resolved and the undersigned believe the process/facility is ready for startup. 1. The construction and equipment meet design specifications. 2. Safety, operating, maintenance, and emergency procedures are in place and adequate. 3. For new facilities, the initial PrHA has been performed and recommendations have been resolved. 4. Changes made to modify the process/facility have been reviewed and authorized under the Management of Change Program. Authorization For Startup: Title Name Signature Date DOE Contract Manager Facility/Process Manager Engineering Manager Maintenance Manager Training Manager PrHA Team Leader Others as Required 65 DOE-HDBK-1101-2004 Exhibit 2.7 Item Responsible Person Date Forecast Date Completed Controlled Documents Approved SOP’s in Control Room Practice for Maintenance Planning Training Fire Department training � Operator Training/Documentation Evacuation Shutdown Plans Emergency Procedures SOPs Escape Pack Procedures SCBA Procedures Deluge System Training

EPA Hazardous Waste Training Distributed Control Sys. (DCS) Training Site & Local Emergency Procedures HAZCOM Training Employee Training & Certification Safety Shower Training Analytical Procedures (Process Lab) � Supervisor Training/Documentation Evacuation Shutdown Plan Emergency Shutdown Procedures SOP’s Critical Plant Detectors & Alarms Escape Pack Procedures SCBA Procedures Deluge System Training EPA Hazardous Waste Training 66 DOE-HDBK-1101-2004 Exhibit 2.7 Item Responsible Party Date Forecast Date Completed DCS Training / Certification Site & Local Emergency Procedures HAZCOM Training Employee Training & Certification Safety Shower Training Analytical Procedures w/ Control Charts Utilities Mechanical Integrity & Blinds Removed Operator Facilities Operator Shelter SCBA Available Escape Packs Available � Safety Showers Low pressure Alarm- Safety Showers All Showers checked & working Clearly Marked & Unobstructed � Fire protection Fire extinguishers in place Hydrants & Monitors Required Fire Hoses in Place Electric Fire Water Pumps Diesel Fire Water Pumps System Integrity Assurance & Alarms Control Room Alarms Hydrocarbon Monitors & Alarms � Electrical Required Electrical Systems in Place Lighting Adequate 67 DOE-HDBK-1101-2004 Exhibit 2.7 Item Responsible Party Date Forecast Date Completed Covers on Panels per OSHA Standards Seals Poured Temporary Power Out of Operating Areas � Instrument Air Instrument Air is Dry Dry Air Alarm Working Backup System Tested � Chilled Water Chilled Water Circulating Orifice Plates Properly Installed � 250-psg Steam Orifice Plates Properly Installed Control Loops Checked System Commissioned � 40 psig Steam Orifice Plates Properly Installed Control Loops Checked 40 lb Letdown 40 lb Vent Steam Tracer Circuits Active Desuperheaters System Commissioned Distributed Control System (DCS) System Problems Cleared Alarms & Trips at Proper Settings Field Switch Alarm & Trip Settings Daily Check of Analyzer Zero & Span Graphics Correct 68 DOE-HDBK-1101-2004 Exhibit 2.7 Item Responsible Party Date Forecast Date Completed Required Loops Checked and Working Propane Adequate Inventory Level Supplier Delivery Schedule Unloading Personnel Training Unloading Compressor Trips in Service Product Tanks Ready to Receive Product-Blinds Out Operator Training to Prevent Overfill Quality Assurance Management System Control Room Operator Facilities SCBA Available Escape Packs Available Acid Suit Available Acid Suit Procedures & Training for Use Monitoring Equip. Test Calibration Process Control System Tested TV Monitor Working Wet Lab in Service Lab Procedures & Data Sheets Present Standard Solutions & Equip. Checked Quality Standards Run on Schedule Fire Protection (Control Room) All Alarm Panels in Service Ventilation Ventilation Shutdown Tested Detectors/Alarms Tested 69 DOE-HDBK-1101-2004 Item Responsible Party Date Forecast Date Completed Fire Extinguishers in Place System Specific Checkouts (Tailor to process) 70 DOE-HDBK-1101-2004 2.8 Mechanical Integrity 29 CFR 1910.119 (j) (1) Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process equipment: (i) Pressure vessels and storage tanks; (ii) Piping systems (including piping components such as valves); (iii) Relief and vent systems and devices; (iv) Emergency shutdown systems; (v) Controls (including monitoring devices and sensors, alarms, and interlocks) and, (vi) Pumps.

(2) Written procedures. The employer shall establish and implement written procedures to maintain the ongoing integrity of process equipment. (3) Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that the employee can perform the job tasks in a safe manner. (4) Inspection and testing. (i) Inspections and tests shall be performed on process equipment. (ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. (iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturer’s recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. (iv) The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. (5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d)) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. (6) Quality assurance. (i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. (ii) Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer’s instructions. (iii) The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used. Intent The purpose of the mechanical integrity element is to ensure the integrity and safe operation of process equipment through inspection, testing, preventative maintenance, and quality assurance. The preventative maintenance program must be proactive rather than reactive, encompassing all equipment used to process, store, or handle HHCs from installation through retirement. 71 DOE-HDBK-1101-2004 Equipment in contact with HHCs forms the first line of defense in preventing uncontrolled catastrophic HHC releases. The second line of defense is typically a combination of containment and safety systems. For example, controlled releases of chemicals may be made to surge or overflow tanks, to diked areas or controlled drainage systems, or through pressure relief valves or vents to scrubbers, filtration systems, or flares. Second line systems also include chemical detection systems and fire detection and suppression systems. The mechanical integrity program must ensure that components in both primary and secondary lines of defense are designed, installed, and operated properly. Corresponding DOE Programs and Requirements

Most contractors already have preventative maintenance programs for their facilities. These programs must comply with maintenance management requirements contained in DOE O 420.1A, FACILITY SAFETY, and DOE O 430.1B, REAL PROPERTY ASSET MANAGEMENT which address most requirements of the Mechanical Integrity element with little modification. DOE’s quality assurance program described in DOE O 414.1A Chg 1, QUALITY ASSURANCE and DOE G 414.1-2, QUALITY ASSURANCE MANAGEMENT SYSTEM GUIDE FOR USE WITH 10 CFR 830.120 AND DOE O 414.1A Chg 1 helps to ensure that process equipment meets specifications and is properly installed. Configuration control and management requirements found in DOE O 430.1B also help ensure the mechanical integrity of process equipment. The DOE safety analysis process can help to focus mechanical integrity programs on safety critical systems, components, and structures. Documentation Requirements Written procedures are required for maintenance operations including the inspection, testing, maintenance, and repair of process equipment. Inspections and tests must be documented and must include the date, the name of the person performing the inspection or test, identification of the equipment examined or tested, the nature of the test or inspection, and results. Deficiencies must be corrected before the equipment is returned to service, or it must be tracked to ensure that corrective action is taken in a safe and timely manner. A system must be in place to track, address, and close out deficiencies identified during inspection and testing. Routine maintenance activities should also be documented. Documentation of the training of maintenance workers on the process, related hazards, and applicable procedures should be consistent with documentation requirements noted in Section 2.5. Minimum Implementation Criteria Maintenance and quality assurance programs are crucial for fabrication, installation, and repair of process equipment. When inspection and testing identify conditions outside of safety limits, deficiencies must be repaired before operations are resumed. If it is not possible to stop operations, actions must be taken to ensure safe operations so that corrective actions can be made in a safe and timely manner. The program to ensure the mechanical integrity of process equipment should contain: 72 DOE-HDBK-1101-2004 • written maintenance procedures [Q75,Q76]; • trained process maintenance personnel; • inspection and test procedures; • scheduled inspection, testing, and maintenance of process equipment; • a quality assurance (QA) program to verify that - for new construction, equipment is suitable for its intended use and is properly installed according to design specifications and manufacturer’s recommendations; - replacement parts and maintenance materials are suitable for the process application in which they will be used; • a preventive maintenance program that includes - pressure vessels and storage tanks; - piping systems, including valves; - relief and vent systems and devices; - emergency shutdown systems; - controls, such as monitoring devices, sensors, alarms, and interlocks [Q77]; and - pumps [Q79].

Although the PSM Rule does not specifically require inspectors to be certified, it does require that qualified personnel be used. In addition, industry standards and guidelines, as well as state regulations, may require certification as evidence of qualification. All workers performing quality assurance, maintenance, inspection and testing tasks must be trained in an overview of the process, the process hazards, and the relevant written maintenance procedures for the covered process [Q77]. DOE contractors may apply training provisions (Section 2.5) for initial and refresher maintenance training, documentation, and grandfathering [Q80]. The frequency of inspections, testing, and replacement should be consistent with accepted standards and codes and manufacturer recommendations. In addition, prior testing, inspection, and operating records can better determine whether more frequent tests, inspections, or replacements are needed. These records should also be used to establish testing, inspection, or replacement frequencies for equipment not covered by codes and standards. Contractors are responsible for ensuring that installations performed by subcontractors are consistent with design specifications and manufacturer’s instructions. Thus, contractors may need to be involved in the reviews, inspections, certifications, and quality assurance work performed by their subcontractors [Q79]. Questions 75. Must equipment-specific maintenance procedures be written for every type of maintenance activity performed on the equipment? Can generic procedures for preventive maintenance be used? DOE contractors may use generic written maintenance procedures for some classes of components and activities (e.g., lubrication of bearings on a class of rotating machinery). On the other hand, for some combinations of equipment and activities, unique written procedures should be developed. 73 DOE-HDBK-1101-2004 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. 77. What are process equipment-type controls? Are all controls and interlocks included in 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 storage 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 comprehensi