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Process Hazard Analysis (PHA's) & Management of Change
Process Hazard Analysis (PHA's) & Management of Change
Block Diagram
P&ID
Process Equipment
Numbering
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
All Events
All Deviations
All Causes
All Consequences
All Safeguards
All Recommendations
Column, Begin:
Reviewing Defense
Designs
Warning/Alarms to
Warn of Deviations
Relief Systems
Ventilations Systems
Implementation of
Engineering
Controls to Minimize
Potential of
Releases
Management of Change
1910.119(I)
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
Management of Change
(MOC)We Must
Define
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
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
parts list
Evaluate change against vent, relief, and flare
capability
Complete industrial hygiene review
Review change against existing
environmental permits
Obtain required approvals
(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.
Management of Change
Summary
We must establish and implement written
Technology to:
Perform
Document
Track
Adjust
Maintain
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