Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Process Hazard Analysis (PHA’s) &

Management of Change
Process Hazard Analysis (PHA)
1910.119(e)
Process Hazard Analysis
(PHA’s)
 Arguably the Most Difficult Part of
Performing the Standard
 Performed by Your PSM Team
 Takes Significant Time & Effort

Remember…
Remember…
Block Diagram
P&ID
Process Equipment
Numbering
You Developed a List of
Equipment Elements
Choose a PHA Process Method
•Must select a process hazard analysis (PHA) method
–What-If;

–Checklist;

–What-If/Checklist;

–Hazard and Operability Study (HAZOP);

–Failure Mode and Effects Analysis (FMEA);

–Fault Tree Analysis

The PHA Must Address:

 Equipment in the process
 Hazards of the process
 Identification of previous incidents

 Engineering and administrative controls

 Consequences of failure
 Facility sitting

 Human factors
 Qualitative evaluation of Safety and Health effects

 Consequences of deviation

 Steps required to correct or avoid deviation

Let’s Choose the “What If”
Method
What If
 In a What hazard analysis,
brainstorming techniques, in the form of
What If questions are used to identify
What
possible deviations and weaknesses in
design. Once identified, these concerns
and their potential consequences are
evaluated for risk.
PHA What if Method
PHA Risk Analysis
PHA Risk Analysis
Process Hazard Analysis

 A PHA Process Must be
Performed on Each
Component of the
Covered Process:

 A PHA From Block
Diagram to P&ID to
Every Equipment
Component to
Determine What Might
Happen if a Component
of the Covered Process
Fails
…Continue the PHA

Continue the PHA

Process UNTIL…
…Continue the PHA

All Components
…Continue the PHA

All Deviations
(Nodes)
…Continue the PHA

All Causes
…Continue the PHA

All Consequences
…Continue the PHA

All Safeguards
…Continue the PHA

All Risk Levels

…Continue the PHA

All Recommendations
…Continue the PHA

Are Completed for

1. Every Component of…
2. Every P&ID of…
3. Every Block Diagram
Section…
4. Of the Entire Covered Process
5. Is Complete
…Continue the PHA

This Process Might

Entail Thousands of
Covered Process
Components &
Procedures
…and Take Years to
Complete
Establish a Project Tracking
Method for all PHA Activities
What Do We Do With the
PHA’s Developed?

 Using the Risk
Column, Begin:
 Reviewing Defense
Designs
 Warning/Alarms to

Warn of Deviations
 Relief Systems

 Ventilations Systems

What Do We Do With the
PHA’s Developed?
With Those Analysis
Complete:


 Begin
Implementation of
Engineering
Controls to Minimize
Potential of
Releases
Management of Change
1910.119(I)
What if Our PHA’s Reveal the
Need to Change Something In
our System to Minimize the
Potential for Release…

We Must Use Management of Change

(MOC)
Management of Change -
Why?

 Many of the
catastrophic accidents
over the past few
decades can be
traced, in large part, to
a management of
change system that
was not in place or
was not functional
Flixborough,
(e.g., Flixborough,
Bhopal).
Management of Change
(MOC)…We Must
 Explain the purpose of MOC
 Set the provisions to be considered for
temporary change
 Define and give example of change in
equipment that requires MOC
 Define and give examples of changes in
procedures when need
 Define and give examples of change in
process technology
 Management of Change
(MOC)…We Must
 Define and give example of a major change
 Define and give example of a minor change
 Define and give examples of "replacement in kind”
 Describe and list the procedures required for
initiating and completing a MOC
 What Do We Do With the
PHA’s Developed?

 Any Changes in
Defense Designs, or
System Engineering will
Require Management of
Change

 P&ID
 Equipment Lists

 Inspection/Testing/

Maintenance Procedures
PHA’s
 PHA’s

Management of Change (MOC)


 MOC procedure should ensure that
equipment and procedures are returned to
their original conditions at the end of a
temporary change
 MOC forms/clearance sheets are acceptable
control methods of tracking changes
 More complex changes require a more
"formal hazard evaluation" than simple
changes (PHA not specifically mentioned).
Management of Change (MOC)
- Pre-Modification Issues

 Check codes, standards, internal engineering
specifications
 Complete design review

 Perform reactivity testing for new substances
 Add materials to TSCA/SARA inventories
 Complete safety and health impact review

 Comply with safety and loss prevention
requirements
Management of Change (MOC)
- Pre-Modification Issues

 Complete maintenance review/revise spare
parts list
 Evaluate change against vent, relief, and flare
capability
 Complete industrial hygiene review

 Review change against existing
environmental permits
 Obtain required approvals
Management of Change (MOC)
- Post-Modification Issues

 Completed Process Safety Systems Review
or Pre-Start
Pre-Start Up Safety Review (PSSR)
 Completed training on change for affected

employees
marked-up
 SOPs marked-up

 P&IDs, PFDs,
PFDs, plot plans and other affected
marked-up
Process Safety Information (PSI) marked-up
 Training program modifications identified
 Preventive maintenance program

modifications identified
Management of Change


 Must Have a
Method for Request,
Tracking,
Completion and
Other Systems
Affected.
Process Hazard Analysis
Summary
 The Process Hazard Analysis is the
Backbone of the Process Safety
Management Program.
 It Provides the Structure Upon Which
PSM is Built
 It Makes Available Pertinent Data &
Safety Information to Design an
Effective PSM Safety Program
Management of Change
Summary

 We must establish and implement written
procedures to manage changes except
"replacements in kind" for a covered process.
 If a Change in Design or Components is

Required, Management of Change Must be
Employed, Tracked, and Analyzed.
PHA’s, P&ID’s
 All PHA’s,
 P&ID’s & Required Procedures
Must be Revised
Work-site employees and contract employers
 Work-site

must be informed and trained on the changes
start-up.
prior to start-up.
PSM Documentation -
Technology Use

 Consider the Use of
Technology to:
 Perform
 Document

 Track

 Adjust

 Maintain


The PSM Program

 What’s Next?

In the Next Session, we

will Cover the Standard
Operating Procedures
and Safety Programs
That Must Be Developed
Based on the Results of
the PHA’s