Process Safety Management of Highly Hazardous & Explosive ChemicalsProcess 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 StandardPerformed by Your PSM TeamTakes Significant Time & Effort

Remember

Block Diagram

P&ID

Process Equipment Numbering

You Developed a List of Equipment Elements

Choose a PHA Process MethodMust select a process hazard analysis (PHA) methodWhat-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 processHazards of the processIdentification of previous incidentsEngineering and administrative controlsConsequences of failureFacility sittingHuman factorsQualitative evaluation of S and H effectsConsequences of deviationSteps required to correct or avoid deviation

Lets Choose the What If MethodIn 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 AnalysisA 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 PHAContinue the PHA Process UNTIL

Continue the PHAAll Events

Continue the PHAAll Deviations

Continue the PHAAll Causes

Continue the PHAAll Consequences

Continue the PHAAll Safeguards

Continue the PHAAll Risk Levels

Continue the PHAAll Recommendations

Continue the PHAAre Completed for Every Element ofEvery P&ID ofEvery Block Diagram SectionOf the Entire Covered Process5. Is Complete

Continue the PHAThis Process Might Entail Thousands of Covered Process Elementsand 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 DesignsWarning/Alarms to Warn of DeviationsRelief SystemsVentilations 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 Change1910.119(I)

What if Our PHAs Reveal the Need to Change Something In our System to Minimize the Potential for ReleaseWe 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 MustExplain the purpose of MOCSet the provisions to be considered for temporary changeDefine and give example of change in equipment that requires MOCDefine and give examples of changes in procedures when needDefine and give examples of change in process technology

Management of Change (MOC)We MustDefine and give example of a major changeDefine and give example of a minor changeDefine and give examples of "replacement in kindDescribe 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 ChangeP&IDEquipment ListsInspection/Testing/ Maintenance ProceduresPHAs

Management of Change (MOC)MOC procedure should ensure that equipment and procedures are returned to their original conditions at the end of a temporary changeMOC forms/clearance sheets are acceptable control methods of tracking changesMore complex changes require a more "formal hazard evaluation" than simple changes (PHA not specifically mentioned).

Management of Change (MOC) - Pre-Modification IssuesCheck codes, standards, internal engineering specificationsComplete design reviewPerform reactivity testing for new substancesAdd materials to TSCA/SARA inventoriesComplete safety and health impact reviewComply with safety and loss prevention requirements

Management of Change (MOC) - Pre-Modification IssuesComplete maintenance review/revise spare parts listEvaluate change against vent, relief, and flare capabilityComplete industrial hygiene reviewReview change against existing environmental permitsObtain required approvals

Management of Change (MOC) - Post-Modification IssuesCompleted Process Safety Systems Review (PSSR)Completed training on change for affected employeesSOPs marked-upP&IDs, PFDs, plot plans and other affected Process Safety Information (PSI) marked-upTraining program modifications identifiedPreventive maintenance program modifications identified

Management of ChangeMust Have a Method for Request, Tracking, Completion and Other Systems Affected.

Process Hazard Analysis SummaryThe 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 SummaryWe 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 RevisedWork-site employees and contract employers must be informed and trained on the changes prior to start-up.

PSM Documentation - Technology UseConsider the Use of Technology to:PerformDocumentTrackAdjustMaintain

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