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…
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 in the process
 Hazards of the process
 Identification of previous incidents
Identification
 Engineering and
Engineering and administrative controls
 failure
Consequences of failure
 Facility sitting
Facility
 factors
Human factors
 Qualitative evaluation of of S and
and H effects
 Consequences of deviation
 deviation
Steps required to correct or avoid deviation
Let’s 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
A PHA Process
Process Must
Must be be
Performed on
Performed on Each
Each
Element of
Element of the
the Covered
Covered
Process:
Process:
 A PHA
A PHA From
From Block
Block
Diagram to P&ID to
Every Equipment
Every Equipment
Element to Determine
What Might
What Might Happen
Happen ifif
an Element of the
Covered Process
Covered Process Fails
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
PHA’s Developed?
 Using the Risk
Begin:
Column, Begin:
 Reviewing Defense
Designs
Designs
Warning/Alarms to
 Warning/Alarms to
Warn of
Warn of Deviations
Deviations
Relief Systems
 Relief Systems
Ventilations 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
(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
requires MOC
MOC
 Define and
and give examples of changes
changes in
procedures when need
 Define and
and give examples of change in
process technology
 Management of Change
(MOC)…We Must
 Define and give example of a major change
 Define
Define and
and give
give example
example of a minor change
change
 Define
Define and
and give
give examples
examples of
of "replacement
"replacement
in
in kind”
kind”
 Describe
Describe andand list the
the procedures
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
P&ID
Equipment Lists
 Equipment Lists
Inspection/Testing/
 Inspection/Testing/
Maintenance Procedures
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
change
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
 inventories
Add materials to TSCA/SARA inventories
 Complete safety and health impact review
Complete
 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
Complete hygiene review
review
 Review change against existing
environmental permits
 Obtain required approvals
Management of Change (MOC)
- Post-Modification Issues
 Process Safety Systems
Completed Process Systems Review
Review
(PSSR)
 training on change for affected
Completed training
employees
 SOPs marked-up
 plans and other affected
P&IDs, PFDs, plot plans
Process Safety Information (PSI) marked-up
 identified
Training program modifications identified
 Preventive maintenance program
modifications identified
Management of Change
 Must Have a Method
for Request,
for
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
We 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 PHA’s, P&ID’s & Required Procedures
Must be Revised
 employers
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
 Track
Adjust
 Adjust
Maintain
 Maintain

The PSM
The PSM Program
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