PROCESS HAZARD ANALYSIS (PHA)
Process Hazard Analysis (PHA) - Facilities are required to review the hazards associated with the regulated substance(s) to identify possibilities of equipment malfunction or human error, and the steps needed to monitor or detect releases. PHAs help minimize releases and provide a forum for ammonia system operators to share critical operating knowledge.
A PHA is required every five (5) years or sooner if the facility incurs a major change (40 CFR 68.50(d) & 68.67(f) and 29 CFR 1910.119). A well designed PHA should identify all failure scenarios that could lead to significant ammonia exposure of workers, the public, or the environment. The facility must keep all PHAs for the life of the process. Referring to former PHAs ensures that past errors are not repeated and assists with the process of keeping the PHA current.
The Process Hazard Analysis is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The employer must perform an initial process hazard analysis (hazard evaluation) on all processes covered by this standard. The Process Hazard Analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process.
First, employers must determine and document the priority order for conducting Process Hazard Analyses based on a rationale that includes such considerations as: the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process.
At least every 5 years after the completion of the initial Process Hazard Analysis, the Process Hazard Analysis must be revalidated by a team meeting the standard's requirements to ensure that the hazard analysis is consistent with the current process.
Employers must keep on file and make available to OSHA, on request, Process Hazard Analyses, updates, and revalidations for each process covered by PSM, as well as the documented resolution of recommendations, for the life of the process.
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