Process Safety Management

of Highly Hazardous &

Explosive Chemicals

Process Hazard Analysis (PHAs) &

Management of Change

Process Hazard Analysis (PHA)

1910.119(e)

Process Hazard Analysis

(PHAs)
Arguably the Most Difficult Part of

Performing the Standard

Performed by Your PSM Team
Takes Significant Time & Effort
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 S and H effects
Consequences of deviation
Steps required to correct or avoid deviation

Lets Choose the What If

Method
In a

What If hazard analysis,

brainstorming techniques, in the form of
What If questions are used to identify
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
Element of the Covered
Process:
A PHA From Block
Diagram to P&ID to
Every Equipment
Element to Determine
What Might Happen if
an Element of the
Covered Process Fails

Continue the PHA

Continue the PHA

Process UNTIL

Continue the PHA

All Events

Continue the PHA

All Deviations

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 Element 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
Elements
and Take Years to
Complete

Establish a Project Tracking

Method for all PHA Activities

What Do We Do With the

PHAs 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

PHAs Developed?
With Those Analysis
Complete:
Begin

Implementation of
Engineering
Controls to Minimize
Potential of
Releases

Management of Change
1910.119(I)

What if Our PHAs 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
(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

PHAs Developed?
Any Changes in

Defense Designs, or
System Engineering will
Require Management of
Change

P&ID
Equipment Lists
Inspection/Testing/
Maintenance Procedures
PHAs

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

(PSSR)
Completed training on change for affected
employees
SOPs marked-up
P&IDs, PFDs, plot plans and other affected
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.
All PHAs, P&IDs & Required Procedures Must
be Revised
Work-site employees and contract employers
must be informed and trained on the changes
prior to start-up.

PSM Documentation Technology Use

Consider the Use of

Technology to:

Perform
Document
Track
Adjust
Maintain

The PSM Program

Whats 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 PHAs