Process Hazard Analysis Revalidations

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Process Hazard Analysis Revalidations
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Process Hazard Analysis RevalidationsRequirements
Purpose

• What are the requirements?
• Revalidate and update the Process Hazard Analysis
  at least every five years after its initial or
  previous completion.
• Revalidation to be performed by a qualified team.
• Whats the purpose?
• Comply with the OSHA PSM 29 CFR 1910.119(e)(6)
  and EPA RMP 40 CFR 68.67(f) regulations.
• Ensure that the PHA is consistent with the
  current process.

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Process Hazard Analysis RevalidationsPhilosophy
To Re-do or Read Through?

• How should I decide?
• Thoroughness of the initial or previous PHA
• Did we re-do or read through five years ago?
• Who was present in the previous PHA?
• Changes to the process in the last five years
  significant or minor?

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Process Hazard Analysis RevalidationsPhilosophy
To Re-do or Read Through?

• OSHA Letter of Interpretation (June 28, 2998)
• Employers must establish the scope and extent of
  their PHA updates and revalidations to include at
  least the following evaluations of existing PHAs
  for accuracy and completeness using the criteria
  set forth in 1910.119(e)(3)
• checks to ensure that modifications to processes
  since the last PHAs have gone through management
  of change procedures or PHAs when required and
  that those changes are reflected in the PHAs
• an evaluation of process safety information (PSI)
  to ensure that it is complete, current and
  accurate
• verifications to ensure PHA specified procedures
  are adequate, up-to-date and are being
  implemented
• determinations that existing PHA recommendations
  have been documented in their required respective
  areas such as PSI, PHAs, and procedures
  (operating, mechanical integrity, emergency
  response, etc.) and have been implemented
• a review of all incident investigation reports
  required by 1910.119(m) to assure all affected
  PSI, procedures, training, etc., have been
  updated to reflect recommendations set forth in
  the subject reports and that appropriate
  information from those reports have been
  incorporated into the PHAs.
• Finally, OSHA intends that the PHA update and
  revalidation be documented.

OSHA
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Process Hazard Analysis RevalidationsPreparing
for the PHA - Summary

• Review implementation status of previous PHA
  recommendations.
• Verify accuracy of PSI
• Piping diagrams
• Normal operating conditions
• Safety systems
• List any changes to the process in the last five
  years (i.e., MOC review).
• Review five year accident history / incident
  investigation records.
• Ensure SOPs are current.

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Process Hazard Analysis RevalidationsPreparing
for the PHA RAGAGEP

• Define recognized and generally accepted good
  engineering practices (RAGAGEPs) used to design,
  operate, and maintain your process.
• Mechanical, Fire, and Building Codes
• Standards ANSI/ASHRAE 15, ANSI/IIAR 2
• Guidelines IIAR Bulletins
• Manufacturers Recommendations

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Process Hazard Analysis RevalidationsPreparing
for the PHA RAGAGEP

• IIAR Bulletin 109 Safety System Inspections
• IIAR Bulletin 110 Maintenance Schedules
• IIAR Bulletin 111 Ventilation Design and
  Maintenance
• IIAR Bulletin 114 Labeling
• ANSI / ASHRAE Standard 15 Ammonia Relief
  Discharge Locations
• ANSI/IIAR 2 Ammonia Sensor Settings and Actions
• ANSI/IIAR 2 E Stop Locations
• EPA Ammonia Refrigeration System Alert Bulletin

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Process Hazard Analysis RevalidationsPreparing
for the PHA Selecting the PHA Methodology

• The PHA methodology must be appropriate to
  determine and evaluate the hazards of the process
  being analyzed. 40 CFR 68.67(b) 29 CFR
  1910.119(e)(2)
• What If Analysis
• Develop what if questions around equipment
  failures, process upsets, and human factor
  issues.
• Hazard and Operability Study (HAZOP)
• Use of Guidewords to identify deviations from the
  design intention.
• Checklists

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Process Hazard Analysis RevalidationsPreparing
for the PHA Whos on your team?

• The PHA shall be performed by a team with
  expertise in engineering and process operations,
  with at least one employee who has experience and
  knowledge specific to the process being analyzed.
  Also, one member of the team must be
  knowledgeable in the specific PHA methodology
  being used. 40 CFR 68.67(d) 29 CFR
  1910.119(e)(4)
• Design Engineers
• Operations and Maintenance Personnel
• Refrigeration Contractor
• Safety / Environmental Management
• PHA Leader Recorder
• Regulatory Representative

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Process Hazard Analysis RevalidationsPerforming
the PHA

• Identify hazards associated with the process
  using selected methodology.
• Determine causes and consequences of each
  potential hazard.
• Discuss any incidents that have occurred at your
  facility in relation to each potential hazard.

• Identify the administrative and engineering
  safeguards associated with each potential hazard.
• Determine risk ranking for each hazard discussed.
• Postulate mitigation measures to reduce the
  consequences and/or likelihood of each potential
  hazard.

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Process Hazard Analysis RevalidationsPerforming
the PHA
HAZOP Guide Words

• Composition Change
• Contamination
• Relief
• Instrumentation
• Sampling
• Corrosion/Erosion/Materials of Construction
• Service Failure
• Abnormal Operation
• Maintenance
• Ignition
• Spare Equipment
• Safety

• No Flow
• Reverse Flow
• More Flow
• Less Flow
• More Level
• Less Level
• More Pressure
• Less Pressure
• More Temperature
• Less Temperature
• More Viscosity
• Less Viscosity
• Agitation

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Process Hazard Analysis RevalidationsPerforming
the PHA

• Risk Ranking
• Qualitative Definitions of Probability of
  Occurrence of an Accident
• (Frequency Ranking)
• A Frequent 0 to 1 years
• More than once per year
• B Periodical Every 1 to 10 years
• At Least once each decade
• C Occasional Every 10 to 100 years
• Probably during the life of the plant
• D Possible Every 100 to 10,000 years
• Not expected at this plant, but could occur
• E Improbable Not for 10,000 or more years
• Not expected or likely to occur at all

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Process Hazard Analysis RevalidationsPerforming
the PHA

• Risk Ranking
• Qualitative Definitions of Severity of
  Consequences to
• People During an Accident (Criticality Ranking)
• I Catastrophic Results in death
• (or damage and production losses gt
  1,000,000)
• II Severe Results in multiple injuries
• (or losses between 100,000 and 1,000,000)
• III Moderate Results in a single injury
• (or losses between 10,000 and 100,000)
• IV Slight Results in operational problems only
• (or losses lt10,000)

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Process Hazard Analysis RevalidationsPerforming
the PHA

• RISK MATRIX
• RISK CODE
• 1 - Critical
• 2 - Undesirable
• 3 - Acceptable with controls
• 4 - Acceptable

Consequences Frequency Frequency Frequency Frequency Frequency
Consequences A Frequent B Periodical C Occasional D Possible E Improbable
I Catastrophic 1 1 2 4 4
II Severe 1 2 3 4 4
III Moderate 2 3 4 4 4
IV Slight 4 4 4 4 4
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Process Hazard Analysis RevalidationsPerforming
the PHA
RISK MATRIX Risk Code 1 Critical Must be
improved Mitigate within six months with
administrative or engineering controls (to
reduce the risk code to 3 or more) 2
Undesirable Should be improved Mitigate
within one year with administrative or
engineering controls (to reduce the risk
code to 3 or more) 3 Acceptable With
Controls Verify need for engineering controls,
or that administrative controls are in place
for hazard 4 Acceptable No mitigating action
required for identified hazard
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Process Hazard Analysis RevalidationsPerforming
the PHA
Project Title Project No Date
PID Title Drawing No HAZOP Session
PID Title Drawing Revision No HAZOP Leader
Process Description Process Description Process Description
Node A Node A Node A
Deviation Causes Consequences C Safeguards F R Recommendations / Comments
Design Notes
No Flow
Less Flow
More Flow
Reverse Flow
More Level
Less Level
More Pressure
Less Pressure
More Temperature
Less Temperature
Viscosity
Agitation
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Process Hazard Analysis RevalidationsPerforming
the PHA
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Process Hazard Analysis RevalidationsPerforming
the PHA

• Ensure the previous PHA adequately satisfied the
  requirements of a PHA
• Previous incidents
• Safeguards and the consequences of the safeguard
  failing.
• Engineering and administrative control
  relationships.
• Facility Siting
• Engine Room exhaust vs. Ventilation Intake
• Roof Hazards
• Access to Eyewash / Safety Showers
• Human Factors
• Qualitative Assessment of Frequency and
  Consequences

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Process Hazard Analysis RevalidationsRecommendati
on Tracking

• Develop a written schedule for completing action
  items.
• Assign responsibilities.
• Meet periodically to review status of
  recommendations and ensure progress is being
  made.
• Document recommendation review meetings and
  actions taken to implement recommendations.
• Maintain evidence that shows progress or
  completion of action items.
• Review status/outcomes with operating,
  maintenance, and any other persons who are
  affected by the recommendations.

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Process Hazard Analysis RevalidationsDocumentatio
n

• All Process Hazard Analysis Study reports must be
  maintained for the life of the process.
• Including recommendation resolution.
• Sign In Sheets.
• Piping Diagrams from the date of the study.
• Team Leader Qualifications.
• Methodology.
• Regulatory Invites as applicable.

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Process Hazard Analysis RevalidationsWhat Can Be
Learned

• Safety improvements.
• Operability improvements.
• Operator wish list.
• Engineering and administrative controls in place
  for handling releases or potential releases.
• Clarify emergency response / action procedures.
• Operator training program.
• Alternative Release Scenarios.