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Auditing the Quality of Process Hazard Analysis (PHA) Studies
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The petrochemical industry is subject to various federal and local regulations and requirements that are challenging to meet and resource-intensive. Time and human factors often lead to a “check box” mentality where requirements are fully complied with “on paper” with little or no emphasis on quality of compliance. Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) requirements are often exposed to this “check box” mentality, especially the Process Hazard Analysis (PHA) element, which is the engine that drives and affects the whole PSM program. Poor implementation of PHA affects mechanical integrity, operating procedures, training, and emergency response, and is considered a root cause of most major incidents. Unfortunately, poor quality PHAs are widespread, hard to identify and can be more dangerous than conducting no PHA at all since it may provide a false sense of safety. Unfortunately, existing literature as well as recognized and generally accepted good engineering practices (RAGAGEP) do not provide sufficient guidelines for assessing PHA quality. The guidelines proposed in this thesis help in properly auditing PHA studies by identifying traps and bad practices that most companies fall into when performing PHAs. The resulting guidelines are developed based on detailed incident investigation reports where root causes included inadequate PHA performance. In addition, expert opinion expressed in published papers highlighting specific gaps in PHA performance, and best practices of PHA implementation are utilized to identify common gaps and means for auditors to acquire evidence of reduced quality. The biggest contributors to the reduction of PHA quality include failing to consider lessons learned previous incidents, reduced quality of PHA inputs such as process safety information, competence of the PHA team members in their respective fields and time allocated for them to complete the PHA, accounting for human factors when relying on operator action to return the process to its safe state, as well as failing to perform PHAs for non-routine mode of operations. These contributors and others are discussed thoroughly on how they affect quality of PHAs and how auditors would obtain evidence that supports lack of quality. The proposed guidelines compiled in Appendix A should be used as part of an overall PSM audit. Using these guidelines by themselves would result in an incomplete assessment of the PHA. This is due to the fact that effective PHA element implementation depends on several other PSM elements that are considered foundational to PHA implementation quality. Spending the time and money to perform an audit utilizing these guidelines should be seen as a positive investment by facility’s executives as it will unquestionably assist in saving a lot of money and ensure business continuity by closing the gaps in PHA performance and reducing the chance for the “check box” mentality, thus making their facilities, employees, community and assets safer.
Process Safety Management
Safety Management System
Alshethry, Faisal Abdulrahman M (2017). Auditing the Quality of Process Hazard Analysis (PHA) Studies. Master's thesis, Texas A & M University. Available electronically from
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