Continuous PHA Revalidation

Operating companies covered by OSHA’s Process Safety Management (PSM) standard or EPA’s Risk Management Program (RMP) rule are required to revalidate their Process Hazard Analysis (PHA) every five (5) years. However, resource-efficient revalidation after a five-year time span can be very challenging. It is not uncommon for an organization to consume resources conducting a complete “redo” PHA. This is due to a multitude of factors, such as:

• Personnel and/or system changes within the organization that make navigating the documentation of the previous PHA nearly impossible.
• Identifying the impact on the PHA from industry and internal incidents or near misses that were either overlooked in the previous PHA or deemed to have adequate protection.
• Inadequate documentation from the previous PHA.

Clearly, PHA revalidation is an essential and critical activity. However, how and when the PHA is performed determines whether it is effective in identifying gaps in design, is ultimately required to prevent incidents.

This paper discusses the merits of an approach geared towards increasing the effectiveness and efficiency of PHA revalidations. Called Continuous PHA Revalidation, this approach may be summarized by asking a simple question:

Every time a change is made or an incident investigation is completed, why not revalidate your existing PHA?