PHA Revalidation per OSHA PSM / EPA RMP

Regulation (Section 2760.2)
(f) At least every five years after the completion of the initial PHA, the PHA shall be updated and revalidated by a team meeting the requirements in section (d): [expertise in engineering and process operations; at least one employee with experience and knowledge specific to the process; one member knowledgeable in the specific PHA methodology being used] to assure that the PHA is consistent with the current process.

(g) The owner/operator shall retain PHAs and updates or revalidations for each covered process, as well as the documented resolution of recommendations for the life of the process.

Five steps of the PHA process:

Identify the hazardous characteristics within the process (of the process materials, of the process, or the equipment).
Identify potential equipment failures or human errors that could lead to accident scenarios that might result in harm.
Evaluate the magnitude of the harm (consequences) and the likelihood of the accident scenarios occurring, then determine the associated risk.
Decide whether that level of risk is tolerable.
For high-risk scenarios, propose risk reduction measures (recommendations) to reduce risk to an acceptable level.

The Reason for Revalidation:

Changes in process or equipment
Gaps and deficiencies in prior PHA
New knowledge (research, incident investigation)
Unresolved recommendations
Regulatory requirements (RMP/PSM)
Changing requirements (company procedure)

Common questions to ask about revalidating PHAs include:

Does your initial PHA meet the minimum requirements necessary under OSHA PSM (external events)?

Have changes received the proper hazard analysis or have undocumented changes created new hazards in the process?

Can you salvage a poor initial PHA or must you spend excessive time and effort to redo it?

Is there a more resource-efficient way to revalidate a PHA?

REVALIDATION APPROACHES:

REDO - perform a complete, new PHA that meets the requirements of OSHA PSM standard, (consideration of external events)
RETROFIT, UPDATE, and REVALIDATE - perform a hazard evaluation of process sections to supplement a previous PHA, address specific deficiencies (human factors, facility siting, etc.) and incorporate the results into the previous PHA; appropriately modify the initial PHA to address changes that have been made to the process; verify that the initial PHA still accurately addresses the hazards of the process and that adequate controls are provided to manage those hazards.
UPDATE AND REVALIDATE - modify the previous PHA as appropriate to address changes that have been made to the process; verify that the initial PHA still accurately addresses the hazards of the process and that adequate controls are provided to manage these hazards.

THE REVALIDATION PROCESS

Collect Supporting Documentation
1. PSI
2. Most recent PHA Report
3. Operating Procedures
4. Management of Change and PSSR documents
5. Previous Incidents Reports
6. Resolution and Status of Recommendations
7. Consequence Assessments (facility siting studies)
8. PSM Compliance Audit Results
Identifying Revalidation Issues
1. Internal and/or External Influences
  1. New regulatory requirements or new interpretations
  2. Possible hazardous interactions of multiple modifications
  3. Minimize the number of documents to be retained (MOC forms, PSSR documents)
2. Initial/Previous PHA Quality
  1. Was the PSI for the previous PHA adequate to assess the hazards?
  2. Were all PHA requirements adequately addressed?
  3. Were the initial/previous PHA results adequately documented?
    For example: The “documentation by exception” approach makes verification of the completeness of the PHA difficult.
  4. Was the analysis technique appropriate?
  5. Was the team composition adequate?
  6. Some companies now require that certified PHA leaders facilitate their analyses.
  7. Were non-routine operations adequately addressed?
  8. Many initial PHAs focus on normal operations and may not address startup, shutdown, or emergency shutdown. One means to address this issue is to perform a hazard evaluation of selected (critical, non-routine) operating and/or maintenance procedures.
3. Operating Experience
  1. Was the initial PHA performed before the processing unit was operating?
  2. When was an effective MOC program implemented?
  3. Have numerous or significant MOCs and/or PSSRs occurred since the last PHA?
  4. Have numerous or major incidents occurred since the previous PHA?
Conducting and Documenting Revalidation Analyses
1. Redo
  Follow established guidelines for conducting a PHA.
2. Retrofit, Update and Revalidate
  Evaluate the previous PHA using a checklist to help identify deficient or missing analyses issues and process unit areas that require Retrofitting, as well as areas that can be Updated and Revalidated.
3. Update and Revalidate
  Documentation from the previous PHA, incident reports, MOC/PSSR documentation, and PHA recommendation status is used to lead them through verification of results from the previous PHA and MOC reviews. Facility siting, human factors, and external events issues for the modifications need to be addressed.

DOCUMENTATION REPORT:

identifies the processing unit examined
lists meeting participants
lists documents examined
describes the revalidation approach
documents analysis results and findings

Format Hazard Evaluation Worksheets to:

simplify revalidation in the future
demonstrate that all analysis issues were addressed
be used to support other PSM activities (mechanical integrity, training)
accurately represent the process configuration, hazards, and applicable controls in one document