Process Hazard Analysis

Revalidations
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 Process Hazard Analysis Revalidations
Requirements & Purpose
What are the requirements?
• Revalidate and update the Process Hazard
Analysis at least every five years after its initial
or previous completion.
• Revalidation to be performed by a qualified
team.

What’s the purpose?

• Comply with the OSHA PSM [29 CFR
1910.119(e)(6)] and EPA RMP [40 CFR
68.67(f)] regulations.
• Ensure that the PHA is consistent with the
current process.
 Process Hazard Analysis Revalidations
Philosophy – To Re-do or Read Through?

How should I decide?

• Thoroughness of the initial or
previous PHA
• Did we re-do or read through
five years ago?
• Who was present in the
previous PHA?
• Changes to the process in the
last five years – significant or
minor?
 Process Hazard Analysis Revalidations
Philosophy – To Re-do or Read Through?
• OSHA Letter of Interpretation (June 28, 2998):
• “Employers must establish the scope and extent of their PHA
updates and revalidations to include at least the following:
evaluations of existing PHAs for accuracy and completeness using
the criteria set forth in 1910.119(e)(3);
• checks to ensure that modifications to processes since the last PHAs have
gone through management of change procedures or PHAs when required and
that those changes are reflected in the PHAs;
• an evaluation of process safety information (PSI) to ensure that it is complete,
current and accurate;
• verifications to ensure PHA specified procedures are adequate, up-to-date and
are being implemented;
• determinations that existing PHA recommendations have been documented in
their required respective areas such as PSI, PHAs, and procedures (operating,
mechanical integrity, emergency response, etc.) and have been implemented;
• a review of all incident investigation reports required by 1910.119(m) to assure
all affected PSI, procedures, training, etc., have been updated to reflect
recommendations set forth in the subject reports and that appropriate
information from those reports have been incorporated into the PHAs.
• Finally, OSHA intends that the PHA update and revalidation be documented.”
 Process Hazard Analysis Revalidations
Preparing for the PHA - Summary

• Review implementation status of previous PHA

recommendations.
• Verify accuracy of PSI:
– Piping diagrams
– Normal operating conditions
– Safety systems
• List any changes to the process in the last five
years (i.e., MOC review).
• Review five year accident history / incident
investigation records.
• Ensure SOPs are current.
 Process Hazard Analysis Revalidations
Preparing for the PHA –
RAGAGEP
• Define recognized and generally accepted good
engineering practices (RAGAGEPs) used to
design, operate, and maintain your process.
• Mechanical, Fire, and Building Codes
• Standards – ANSI/ASHRAE 15, ANSI/IIAR 2
• Guidelines – IIAR Bulletins
• Manufacturer’s Recommendations
 Process Hazard Analysis Revalidations
Preparing for the PHA –
RAGAGEP
• IIAR Bulletin 109 – Safety System Inspections
• IIAR Bulletin 110 – Maintenance Schedules
• IIAR Bulletin 111 – Ventilation Design and
Maintenance
• IIAR Bulletin 114 – Labeling
• ANSI / ASHRAE Standard 15 – Ammonia Relief
Discharge Locations
• ANSI/IIAR 2 – Ammonia Sensor Settings and Actions
• ANSI/IIAR 2 – E Stop Locations
• EPA Ammonia Refrigeration System Alert Bulletin
 Process Hazard Analysis Revalidations
Preparing for the PHA –
Selecting the PHA Methodology

• The PHA methodology must be “appropriate to

determine and evaluate the hazards of the process
being analyzed.” [40 CFR 68.67(b) & 29 CFR
1910.119(e)(2)]
• What If Analysis
• Develop “what if” questions around equipment failures, process
upsets, and human factor issues.
• Hazard and Operability Study (HAZOP)
• Use of Guidewords to identify deviations from the design intention.

• Checklists
 Process Hazard Analysis Revalidations
Preparing for the PHA –
Who’s on your team?
• “The PHA shall be performed by a team with expertise in
engineering and process operations, with at least one
employee who has experience and knowledge specific to
the process being analyzed. Also, one member of the team
must be knowledgeable in the specific PHA methodology
being used.” [40 CFR 68.67(d) & 29 CFR 1910.119(e)(4)]
• Design Engineers
• Operations and Maintenance Personnel
• Refrigeration Contractor
• Safety / Environmental Management
• PHA Leader & Recorder
• Regulatory Representative
 Process Hazard Analysis Revalidations
Performing the PHA
• Identify hazards associated with the process using
selected methodology.
• Determine causes and consequences of each potential
hazard.
• Discuss any incidents that have occurred at your facility in
relation to each potential hazard.
• Identify the administrative and engineering
safeguards associated with each potential
hazard.
• Determine risk ranking for each hazard
discussed.
• Postulate mitigation measures to reduce the
consequences and/or likelihood of each
potential hazard.
 Process Hazard Analysis Revalidations
Performing the PHA
HAZOP Guide Words

• No Flow • Composition Change

• Reverse Flow • Contamination
• More Flow • Relief
• Less Flow • Instrumentation
• More Level • Sampling
• Less Level • Corrosion/Erosion/Materials
• of Construction
More Pressure
• Service Failure
• Less Pressure
• Abnormal Operation
• More Temperature
• Maintenance
• Less Temperature
• Ignition
• More Viscosity
• Spare Equipment
• Less Viscosity
• Safety
• Agitation
 Process Hazard Analysis Revalidations
Performing the PHA
Risk Ranking
Qualitative Definitions of Probability of Occurrence of an Accident
(Frequency Ranking)

A Frequent0 to 1 years
More than once per year

B Periodical Every 1 to 10 years

At Least once each decade

C Occasional Every 10 to 100 years

Probably during the life of the plant

D Possible Every 100 to 10,000 years

Not expected at this plant, but could occur

E Improbable Not for 10,000 or more years

Not expected or likely to occur at all
 Process Hazard Analysis Revalidations
Performing the PHA
Risk Ranking
Qualitative Definitions of Severity of Consequences to
People During an Accident (Criticality Ranking)
I Catastrophic Results in death
(or damage and production losses >
$1,000,000)

II Severe Results in multiple injuries

(or losses between $100,000 and $1,000,000)

III Moderate Results in a single injury

(or losses between $10,000 and $100,000)

IV Slight Results in operational problems only

(or losses <$10,000)
 Process Hazard Analysis Revalidations
Performing the PHA
RISK MATRIX

Frequency
Consequences A: B: C: D: E:
Frequent Periodical Occasional Possible Improbable

I: Catastrophic 1 1 2 4 4
II: Severe 1 2 3 4 4
III: Moderate 2 3 4 4 4
IV: Slight 4 4 4 4 4

RISK CODE
1 - Critical
2 - Undesirable
3 - Acceptable with controls
4 - Acceptable
 Process Hazard Analysis Revalidations
Performing the PHA
RISK MATRIX
Risk Code:

1: Critical Must be improved

Mitigate within six months with administrative or
engineering controls
(to reduce the risk code to 3 or more)

2: Undesirable Should be improved

Mitigate within one year with administrative or
engineering controls
(to reduce the risk code to 3 or more)

3: Acceptable With Controls

Verify need for engineering controls, or that
administrative controls are in place for
hazard

4: Acceptable No mitigating action required for identified hazard

 Process Hazard Analysis Revalidations
Performing the PHA
Project Title: Project No: Date:
P&ID Title: Drawing No: HAZOP Session:
Drawing Revision No: HAZOP Leader:
Process Description:
Node A:

Deviation Causes Consequences C Safeguards F R Recommendations / Comments

Design Notes
No Flow
Less Flow
More Flow
Reverse Flow
More Level
Less Level
More Pressure
Less Pressure
More
Temperature
Less
Temperature
Viscosity
Agitation
 Process Hazard Analysis Revalidations
Performing the PHA
HTS HTRL
FROM D O C K E V A P S T O C O O LE R E V A P O R A T O R S

HTRS
F R O M C O O LE R E V A P O R A T O R S
PRV
T O D IF F U S I O N T A N K

HTRS
HSS

HTRL
HTS
T O HIG H T E M P C O M P R E S S O R S

HPL
F R O M HIG H P R E S S U R E R E C E I V E R

S H IG H T E M P E R A T U E
RECIRCULATOR

P P

3 HP 3 HP
 Process Hazard Analysis Revalidations
Performing the PHA

• Ensure the previous PHA adequately satisfied the

requirements of a PHA:
• Previous incidents
• Safeguards and the consequences of the safeguard
failing.
• Engineering and administrative control relationships.
• Facility Siting
• Engine Room exhaust vs. Ventilation Intake
• Roof Hazards
• Access to Eyewash / Safety Showers
• Human Factors
• Qualitative Assessment of Frequency and
Consequences
 Process Hazard Analysis Revalidations
Recommendation Tracking
• Develop a written schedule for completing action
items.
• Assign responsibilities.
• Meet periodically to review status of
recommendations and ensure progress is being
made.
• Document recommendation review meetings and
actions taken to implement recommendations.
• Maintain evidence that shows progress or
completion of action items.
• Review status/outcomes with operating,
maintenance, and any other persons who are
affected by the recommendations.
 Process Hazard Analysis Revalidations
Documentation

• All Process Hazard Analysis Study reports must

be maintained for the life of the process.
– Including recommendation resolution.
– Sign In Sheets.
– Piping Diagrams from the date of the study.
– Team Leader Qualifications.
– Methodology.
– Regulatory Invites as applicable.
 Process Hazard Analysis Revalidations
What Can Be Learned…

• Safety improvements.
• Operability improvements.
• Operator “wish list”.
• Engineering and administrative controls in
place for handling releases or potential
releases.
• Clarify emergency response / action
procedures.
• Operator training program.
• Alternative Release Scenarios.