PHA Revalidation

1.

Perform a hazard evaluation of all known modifications made to the process since the initial PHAs to confirm that any hazards associated with the modifications are incorporated into the current PHA results. (Note: if the MOC program for the process was not in place and/or ineffective for some period of time after the initial PHAs or if there are an excessive number of MOCs since the initial PHAs, it may be more prudent and/or efficient to redo the PHAs instead.)

Reason:
Necessary to ensure that the updated and revalidated PHAs reflect all the hazards of the current process.

2.

Review incident investigation reports written since the initial PHAs.

3.

Review the status of recommendations from the initial PHAs (especially any recommendations that are still not addressed).

Reason:
Tasks 2 and 3 would accompany any revalidation and are necessary to update the initial PHAs.

4.

Perform or upgrade the evaluation of human factors and/or facility/stationary source siting issues using checklists, especially focusing on how process modifications may have affected these issues.

5.

Discuss the hazards involved with nonroutine operating modes (e.g. startup, shutdown, maintenance, sampling) in the process unit to help identify procedural and/or equipment deficiencies that could contribute to human errors; this could involve a detailed hazard review of selected written procedures for the process, or at a minimum, using these modes of operation as guide words in the hazard analysis.

Reason:
Tasks 4 and 5 are enhancements to the initial PHAs. If the initial PHAs were completed before regulation 29 CFR 1910.119 was issued or shortly thereafter, the PHAs may not have adequately addressed these issues; performing these two tasks will help ensure that the revalidated PHAs comply with the PHA requirements in regulations 29 CFR 1910.119 and 40 CFR 68.

6.

Discuss process releases from each process node to identify releases that could have offsite impacts (i.e. impacts to the public or the environment as defined by EPA's regulation 40 CFR 68).

Reason:
Task 6 provides a revalidated PHA that also meets the requirements of regulation 40 CFR 68.

Q.

Why should I revalidate my PHAs?

A.

U.S. OSHA's process safety management (PSM) regulation (29 CFR 1910.119) requires PHAs to be updated and revalidated every five years. U.S. EPA's risk management program (RMP) rule has similar provisions and adds the requirement of identifying process releases that could have offsite impacts. Also, chemical and petroleum industry standards and most internal company standards require keeping hazard reviews up to date.

Q.

How should I revalidate my PHAs?

A.

The revalidation approach best for your facility depends on several factors:

• What was the quality of the initial PHAs?
• How extensive have changes to the process been?
• How effective has your management of change (MOC) program been?

The answers to these questions will tell you whether you need a Redo, Retrofit, Update, or Revalidation, of your facility’s PHAs. These different types of revalidation are defined below.

Redo: Perform a complete, new PHA that meets the requirements of U.S. 29 CFR 1910.119(e) and 40 CFR 68.67 or similar company standard.

Retrofit: Perform a hazard evaluation of process sections to augment a previous PHA, to address a specific issue, or to address potential offsite consequences under 40 CFR 68.67.

Update: Modify a PHA to account for changes that have been introduced or incidents that have occurred since the previous analysis.

Revalidation: Confirm that a PHA accurately reflects the process hazards given the current equipment configuration, process operations, staffing, and surroundings, and that the analysis meets the requirements of 29 CFR 1910.119(e) and 40 CFR 68.67 or similar company standard.

Q.

Who should be on my PHA revalidation team?

A.

OSHA and EPA require that your PHA revalidation team have the same range of expertise as the team that performed the initial PHAs, but the team members need not be the same team members as the initial PHA.