Process Hazard Analysis

Home > Articles > Process Hazard Analysis By Steve Stephenson August, 2013

OSHA Safety Signs Best Practices Guides A Process Hazard Analysis (PHA) is a thorough, orderly, and systematic method used to identify, evaluate, and determine ways to control the hazards resulting from processes that uses hazardous chemicals. A Process Hazard Analysis is required by both the EPA Risk Management Program (RMP) rules (40 CFR Part 68) and OSHA's Process Safety Management (PSM) standard 29 CFR 1910.119. These regulations require that the Process Hazard Analysis address toxic, fire, and explosion hazards that result from specific chemicals, and that it identify the possible impacts on employees, the public, and the environment.

Process Hazard Analysis Methods

There are a number of ways to conduct a process hazard analysis. The method that is selected must be appropriate for the processes to be analyzed. The analysis must be able to accurately identify and evaluate the chemical hazards associated with the process, and to determine appropriate control measures. The first step is to prioritize the processes which will be examined. The priority should be based on a factors such as:

the extent of the process hazards the number of potentially affected employees the age of the process and condition of the equipment used in the process the operating history of the process.

The processes identified as having the greatest risk should be subject to a Process Hazard Analysis as soon as possible. Both the EPA and OSHA prescribe several methods that may be used for a Process Hazard Analysis. Which method is used depends on the characteristics of the process, the past history of the

process, and the specific situation. The following is a list of the methods that may be used:

What-if Checklist What-if/checklist Hazard and operability study (HAZOP) Failure mode and effects analysis (FMEA) Fault tree analysis

EPA and OSHA also allow alternate methods to be used, as long as they are equivalent to those on the above list.

Process Hazard Analysis Requirements

The EPA requires that a Process Hazard Analysis address the following, without regard to which method is used. It must:

Identify and characterize all of the hazards of the process. Identify all previous incidents that could have had catastrophic consequences. Identify engineering and administrative controls that could be used to control the hazards. Identify methods for detection and providing early warning of releases. Identify the consequences should engineering and administrative controls fail.

This must include a qualitative evaluation, including a range of the potential safety and health effects, should there be a failure of controls.

Identify and evaluate stationary source siting factors. Identify and evaluate human factors.

The Process Hazard Analysis Team

The Process Hazard Analysis must be conducted by a team that has expertise in the engineering related to the process. In addition, the team must include at least one employee who has experience with, and is knowledgeable about the process being evaluated. There must also be one member of the team with knowledge and understanding of the specific Process Hazard Analysis method that will be used.

Findings of a Process Hazard Analysis Methods

Once a Process Hazard Analysis is complete, the findings and recommendations must be addressed promptly. The following must be accomplished:

the response to the teams findings and recommendations must be done in a timely manner.

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develop a written schedule of when the actions are to be completed. complete recommended actions as soon as possible. communicate the actions being taken to operating and maintenance staff. communicate the actions being taken to employees whose work assignments involve the process and who may be affected by the recommendations or actions.

there must be a system in place that verifies that the identified problems and issues were resolved in a timely manner. the actions that were taken must be documented.

Updating and Documentation Requirements

A Process Hazard Analysis must be conducted, on each process that uses hazardous chemicals, at least once every five years. The purpose is to update the findings of the PHA and ensure that the hazard analysis is appropriate for the current design of the process. Each Process Hazard Analysis, each PHA update, and the resolution of each analysis' recommendations, must be documented. The documentation must be available to the EPA or OSHA, should they request it. The documentation must be kept available for the life of the process.

Process Hazard Analysis Methods

Let's take a look at several of the Process Hazard Analysis methods. This overview will provide a rough idea of what a Process Hazard Analysis does and how it accomplishes its goals.

Process Hazard Analysis Checklists

A checklist works best with processes that are covered by regulations, standards, codes, and industry standard practices. A checklist can be created based on what is required by those regulations, codes, etc, and then an inspection verifies that the process meets all of the requirements. An example would be a storage tank designed to ASME standards. The ASME criteria can be used to determine the condition of the storage tank. To begin, a checklist needs to be created using the relevant regulations, standards, codes, and industry practices. The checklist should be formatted as a list of questions that can be answered by either: yes, no, not applicable, or more information needed. variations from the standards. Using a checklist involves walking down the process, and comparing the process conditions and equipment to the items on the checklist. Any variations are identified and analyzed to determine an appropriate response. Responses might involve equipment repairs, process adjustments, changes to monitoring equipment, or even changes to the process. The objective is to use the checklist to identify

What-If Analysis
A What-If analysis involves a group of knowledgeable people, who are familiar with the process, brainstorming what if scenarios. During brainstorming sessions questions are raised about possible variations in the process, possible human error, potential failure points, and other potential causes of process problems or failures. The likelihood and consequences these variations are discussed. Notes are taken on the discussion, and specific areas of investigation are identified. Each question and area is then thoroughly investigated by several of the team members. The What-If analysis looks at the entire process, beginning from the point at which the chemicals arrive, through to the product shipping to customers. The purpose of a What-If analysis is to identify potential hazards, failure points, hazardous situations, and accident scenarios. This includes examining:

deviations from design conditions potential equipment failures

possible human error construction and modification activities operating intent vs. actual operating conditions

The team then suggests possible risk reduction actions and alternatives. This requires that team members be experienced with the process, have a good understanding of the process, and to have the ability to understand cascading failures, and failure conditions that involve multiple factors.

What-If/Checklist
The Checklist and What-If methods can be combined so that each compensates for the weaknesses of the other method. The "What-If" part of the process can help the team identify hazards and accident scenarios that are beyond the experience of the PHA team members. Usually the "What-If" brainstorming process is done first, and will provide guidance by identifying areas the Check/list inspection should more thoroughly examine. The checklist provides a detailed, systematic approach that can catch deviations and problems that might be missed in the brainstorming process. This duo-method approach is excellent for identifying the potential for general types of accidents, qualitatively evaluating the effects of those potential accidents, and determining whether existing safeguards are adequate.

The Hazard and Operability Analysis

The Hazard and Operability Analysis (HAZOP) was originally developed for chemical processing plants to use to identify both hazards and operating problems. HAZOP is particularly well suited for identifying problems when technologies with which the plant staff is not familiar are being used. HAZOP uses a series of meetings in which process drawings are systematically examined to evaluate the impact of deviations. Using the process drawings the team goes through each step in the process. At each process step they use guide words to identify potential negative consequences that could arise from variations or failures. The guide words are:

No More Less Part of As well as Reverse Other than

The process parameters that are examined include flow, pressure, temperature, level, composition, pH, frequency, and voltage. So, for example, at a certain point in the process the questions might be asked concerning the effects of:

No flow? More flow? Less flow? Reverse flow? Other than normal flow?

As the team asks these questions they record possible causes of the deviation, note possible consequences, suggest safeguards, and make recommendations for needed actions. In some cases more information may be needed to evaluate the deviation. The team then assigns people to obtain the needed information, and the analysis continues once that information is available. The object of the HAZOP method is to systematically review the process and identify process deviations that could lead to harmful consequences.

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Process Hazard Analysis Labels and Signs

Don't forget to include labels and signs as a part of your PHA. A missing safety sign can result in needed information not being communicated, resulting in an accident. Be sure that all necessary signs and labels are in place, and that their messages are appropriate for the current process.