Operating hazard analysis updating

The most logical analysis to update is the operating hazard analysis. Updates can generally be accomplished by conducting a new OH A at each update point and/or by conducting a comprehensive change analysis to evaluate the differences in procedures, personnel, plant, and hardware between the original analysis (or last update) and the current analysis. 

Process Hazard Analysis (PHA) (Dowell, 1994, pp. 30-34.) The OSHA rule for Process Safety Management (PSM) of Highly Toxic Hazardous Chemicals, 29 CFR 1910.119, part (e), reqmres an initial PHA and an update every five years for processes that handle listed chemicals or contain over 10,000 lb (4356 kg) of flammable material. The PHA must be done by a team, must include employees such as operators and mechanics, and must have at least one person skilled in the methodology employed. Suggested methodologies from Process Safety Management are listed in Table 26-1. 

As can be seen from the Global Reactive Chemicals Standard, all existing chemical processes will have a Reactive Chemicals/Process Hazard Analysis review on a predefined periodic basis. In addition, every new plant Production Leader should review their process with the Reactive Chemicals Committee within 90 days of assuming responsibility for a pilot or production plant. Prior to the review, the Leader should acquire training on the chemistry and processes that they are working with. This should include an evaluation of raw materials, processes, products and waste to understand any potential reactive chemical hazards. They should review and be prepared to answer questions from the completed and updated RC/PHA protocol questionnaire as well as other relevant materials in their plant Process Safety Folder, such as F EI, CEI, etc. The review should cover all auxiliary operations to the process such as raw material and product storage drum, tank car and truck loading. 

CFR830.6 29CFR1910.119(e)(7) 40CFR68.67(g) 4.2.1.7 Hazard analysis results and documentation, including updates, shall be retained for the life of the process operation... 

Safety is a property of the operational system and therefore safety arguments should address all the operational domain including the normal and degraded modes of the system, its maintenance, data updates and data passed across the boundary of the operational system. System hazard identification and subsequent hazard analysis should consider all system hazards including those that arise from data errors. If data is not considered within the hazard analysis stage, no data-related hazards will be identified, suggesting that the data has no specific safety... 

You must ensure that a hazards analysis (facility level) and a JSA (operations/task level) are developed and implemented for all of your facilities and activities identified or discussed in your SEMS. You must document and maintain a current analysis for each operation covered by this section for the life of the operation at the facility. You must update the analysis when an internal audit is conducted to ensure that it is consistent with your facility s current operations. 

The last step is to conduct follow-up activities. It is important to monitor the system to ensure the effectiveness of the hazard controls and to check for new or unexpected hazards. Things change so it is important to periodically reassess the systan and determine if hazards are still adequately identified and control mechanisms stiU work. This is especially important if the system is modified, expanded, or reconfigured or operating conditions change. If there are any material changes to the system, then the hazard analysis should be updated to reflect the changes and their impacts to the system. 

As with other safety analysis tools, the facility hazard analysis should be performed as early in the program as feasible. The same hazard analysis format can be used, with the columns filled in with preliminary or available information. The facility hazard analysis should be revisited at the 30%, 60%, 90%, and 100% design review stages, updating the worksheets as information becomes available. When the acceptance inspection and operations review is conducted, the facility hazard analysis should again be updated. The same holds for facilities that are modified or retrofitted. 

In order to ensure safety, an adequate degree of fire protection should be provided in nuclear power plants. A fire hazards analysis including consequences of fire fighting should be performed before initial fuel loading and be updated during operation to verify that the main safety functions to shut down the reactor, to remove residual heat, and to contain radioactive material are maintained against the consequences of a fire. 

Where extension of use is conducted as part of a controlled roll out it should be subject to the usual change management procedures which will have been established in the in SMS. Essentially a set of safety activities will need to take place on the product to determine whether the new operating environment introduces any new hazards and the safety case updated accordingly. The analysis will need to be able to justify operating the system outside of the intended purpose and set out the evidence to support the claim that the risk remains acceptable. 

In addition to updated content of the first edition, the revised second edition of the Basic Guide to System Safety has a more expanded and useful glossary of terms it also contains a new chapter describing the basic concept, utility, and function of the hazard and operability study (HAZOP) and what-if analysis. Both of these analytical techniques have been used quite routinely and successfully in the petrochemical industry for decades. As with all analytical methods and techniques presented in this text, it is suggested that the HAZOP smdy and what-if analysis have definite application to general industry operations as well. 

Recommended preventive actions should make it very difficult, if not impossible, for the incident to recur. The investigative report should list all the ways to foolproof the condition or activity. Considerations of cost or engineering should not enter in at this stage. The primary purpose of incident investigations is to prevent future occurrences. Beyond this immediate purpose, the information obtained through the investigation should be used to update and revise the inventory of hazards, and/or the program for hazard prevention and control. For example, the Job Safety Analysis should be revised and employees retrained to the extent that it fully refiects the recommendations made by an incident report. Implications from the root causes of the accident need to be analyzed for their impact on all other operations and procedures [6]. 

Risk analysis is a live document and it should be thoroughly reviewed by the operator whenever there is any change in the system because it is the responsibility of the operator to understand all risks and control measures all the time. Also to improve the quality of risk analysis it is important to validate all hazards/major incident events, likelihood, control measures, and consequence, very rigorously. Proper communication, updating, and education/training are parts of risk management, which is an extension of risk analysis. So far helpful discussions have taken place regarding control measure, but what is control measure The next clause provides the answer. 

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