Why Conduct a Process Hazard Analysis? 

First off, what is a Process Hazard Analysis? 

A Process Hazard Analysis or PHA is a thorough and systematic review of process systems to identify potential component failures or human error that could lead to an accident and/or environmental release.  Where potential failure scenarios are identified, a PHA will determine whether adequate safeguards are in place to protect from major equipment damage, prevent release and personnel exposure to hazardous chemicals, and avoid other significant consequences.  

There are a number of well-established methods for conducting PHAs. A trained PHA Leader will determine which of the available review methods is best suited to address the complexity and relative risk associated with a process facility.  

The best PHA review teams are composed of a multi-disciplinary group of individuals, all of which have a stake in the safety and operability of the process system. This may include system designers, operators, maintenance personnel, and Environmental, Health and Safety professionals. All team members are expected to actively participate in the review process. Organizational hierarchy should be left at the door during the review. Everyone at the table needs to have a voice, and there are no dumb questions when it comes to ensuring safety.  

When do I have to conduct a PHA? 

In the 1970’s and 1980’s, there were a number of major industrial accidents that occurred in Europe, Asia, and the United States that resulted in fires, explosions, and environmental releases. These incidents led to numerous deaths, significant property damage, and lasting environmental impacts. 

In response to these catastrophic events, the U.S. and other countries enacted regulations to ensure that operational risks are identified and mitigated to prevent avoidable disasters such as these. In the U.S, the Occupational Safety and Health Administration (OSHA) developed Process Safety Management standards (29 CFR 1910.199) and the Environmental Protection Agency (EPA) developed Risk Management Program regulations (40 CFR part 68). These regulations require proper management of operations involving highly hazardous chemicals. Both regulations require facilities who are subject to the rule to conduct a PHA before system operations commence, at regular intervals during operations, and whenever changes are made to the operation.  

If your facility uses highly hazardous chemicals in quantities that exceed the quantity thresholds listed in 29 CFR 1910 (Appendix A or 1910.119(a)(1)(ii)) or 40 CFR 68.130, PHAs are required by law.     

If my facility is not covered under the OSHA PSM or the EPA RMP regulations, why should I conduct a PHA? 

Regardless of whether your facility employs highly hazardous chemicals or not, most industrial processes involve some degree of operational risk.  As well-designed and well-built you believe your process system to be, or how talented your operations staff are, it’s worth asking the question “what’s the worst thing that can happen?” That worst case scenario may occur sometime during the operational life of your process if adequate layers of protection are not in place to protect from a component failure or operator mistakes. 

Conducting a PHA will certainly have an impact on the project schedule when implementing a new process at your facility. But it’s worth considering the cost, schedule, and reputation impacts of a system failure due to having inadequate safeguards in place. Ask yourself the following questions; 

• How costly would it be to remediate a significant environmental release due to a process upset? 

• What fines may be imposed if wastewater and vapor streams are out of compliance? 

• What are the consequences if a slug of pure solvent were to be released to the sewer? 

• Are there adequate safeguards in place to protect the safety of your most valuable assets, your employees?  

Additionally, it is your General Duty to identify the hazards of your process. The General Duty Clause from the OSHA Act of 1970 requires that all employers provide a work environment “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Furthermore, Section 112(r)(1) of the Clean Air Act is EPA’s General Duty Clause requires facilities to: know the hazards posed by the chemicals and assess the impacts of possible releases; design and maintain a safe facility to prevent accidental releases; and minimize the consequences of accidental releases that do occur. Therefore, both General Duty Clauses require facilities to identify the hazards of a process (a.k.a. conduct a PHA). These General Duty Clauses apply to facilities that use any hazardous chemicals in any quantities onsite. 

PHAs are a cost-effective risk management and mitigation approach to employ in planning for a safe and compliant process operation. The benefits of conducting a PHA include the following: 

• The process facility will operate more efficiently 
• Product quality will improve  
• The facility will experience less down time 
• Employee involvement in the detailed review process will help staff become more comfortable with the process  

• The company will minimize risk of having its name in the headlines by minimizing the likelihood and severity of accidents 

A PHA review process demonstrates to stakeholders and employees that safety and compliance are critically important at your facility and are worth investing in.