The distribution of OSHA citations concerning CFR 1910.119 (Process Safety Management of Highly Hazardous Chemicals) is approximately as follows:
(Exhibit in full paper)
The number of Process Hazard Analysis (PHA) citations is second only to the number of Mechanical Integrity citations. This paper discusses not only frequently cited PHA shortcomings but also those shortcomings noticed in PSM audits. For convenience, this discussion of shortcomings follows the chronological order of the PHA sequence.
1910.119(e)(6) requires that PHA studies be redone or revalidated on five-year (maximum) intervals. The intention of the standard is that the entire study should be reviewed, not an incremental portion. Additionally, the report date of the previous PHA is the "start date" for timing of the five-year interval. To avoid citations, revalidate or redo the PHA in its entirety at least every five years.
Although this is not a requirement of OSHA, it is now recognized and generally accepted good engineering practice. Over the 15-year interval between three successive studies, it is very likely that internal PHA practices have changed, that regulatory requirements have changed, and that industry practices have changed. Revalidating the same original study again and again renders the PHA team unlikely to recognize and change the affected parts of the PHA. By making "every other PHA a full redo," the PHA facilitator and team are more likely to identify and correct shortcomings that would otherwise be missed.
1910.119(e)(4) requires that PHA teams consist of a minimum of one member with process knowledge of the equipment under review, one member with engineering expertise, and one trained facilitator. Unless the qualifications of these members are recorded in the PHA record, there may be no way in the future to verify that the necessary personnel were present for the team meetings. Always document not only the names but also the qualifications of PHA team members and keep this documentation in the PHA report.
At the time that a PHA is performed, a specific PHA procedure is in effect. Subsequent PHA procedures are likely to include additional requirements that did not exist at the time of a previous PHA. Include the PHA procedure that was used by the team in the PHA report. With the procedure, any auditor can verify that the team followed the requirements that were in effect at the time of the PHA. Without a copy of the PHA procedure used by the team, the auditor may have to evaluate the PHA using the current (and newer) procedure. This would likely lead to citations of shortcomings for an older PHA.
Many companies still attempt to assess risk without having formal severity, likelihood, and risk definitions. Without such metrics, including a "tolerable-risk matrix," there is no way to rank the relative risks associated with PHA scenarios.
