Process Hazard Analysis Regulations

For larger or more complex facilities, a systematic approach to identifying incompatibility scenarios and analyzing their severities and likelihoods may be warranted. A process hazard analysis (PHA) approach such as a hazard and operability (HAZOP) study can be an effective tool to facilitate such an effort, and may be required by regulation if the process falls within the scope of regulations. These methods are discussed in Section 4.5. 

Neither the OSHA PSM Standard nor the EPA RMP regulation explicitly requires specific hazards, such as reactive hazards, to be examined when performing a process hazard analysis. 

RMP requires covered processes to have a hazard assessment, a prevention program, and an emergency response program. The hazard assessment must evaluate the accidental release of regulated substances, including the worst case scenario. RMP contains requirements for prevention of accidental releases, which include the same basic elements as the OSHA PSM Standard. Therefore, the limitations described in Section 5.1.2.2 with respect to process safety information and process hazard analysis also apply to RMP. 

A reactive chemicals/process hazard analysis (PHA) to be completed every three years (see Reference 11). Special consideration may be given to facilities that have lower levels of process risk and which have demonstrated superior safety performance to extend this frequency up to five years. Facilities that pose higher process risk or who have lower safety performance may be recommended to have reactive chemicals/PHA reviews more frequent than every three years. In certain countries, government regulation will determine the frequency and other requirements for Process Hazard Analysis reviews. Dow will follow the government requirements where they are more stringent. 

The reader is reminded that a HAZOP or What-If report is a living document for a facility. As changes are made to a facility or its procedures the HAZOP or What-If review(s) will be updated to represent the current facility. Process hazard analysis reviews are also required to be updated and revalidated every five years as a minimum by U.S. regulations (OSHA and EPA). 

In the aftermath of the Bhopal disaster, OSHA s Process Safety Management (PSM) has come into play and dictates the procedures to minimize the possibility of fire, explosion, or chemical release. If a project contains a regulated hazardous chemical, a process hazards analysis must be conducted to ensure that the likelihood of a fire, explosion, or release of hazardous chemicals is minimized and that equipment and facilities are included to minimize the effects of a fire, explosion, or release, if one does occur. 

P ID PHA PSI PSIC PSISR PSM Piping and Instrumentation Diagram Process Hazard Analysis Process Safety Incident Process Safety Incidents Count Process Safety Incident Severity Rate Process Safety Management (U.S. OSHA Regulation)... 

Table 17.1 shows the aspects of process safety for which actions are required by OSHA in Title 29 of the Code of Federal Regulations, Part 1910, Section 119 (29 CFR 1910.119) [1] and by the EPA in Title 40 of the Code of Federal Regulations, Part 68 (40 CFR 68) [2]. This Chemical Process Safety section concentrates on the engineering aspects of Process Safety Information —on the consequences of failure of engineering and administrative controls and the qualitative evaluation of a range of the possible safety and health effects of failure of controls requirements of the OSHA and EPA Process Hazards Analysis and the Off-Site Hazard Assessment. ... 

The regulation requires that new facilities conduct a process hazards analysis (PHA). The PSSR team should check that the PHA was, in fact, carried out, and that its recommendations were either resolved or implemented. During the pressure of construction, there is sometimes a tendency to postpone some of the PHA recommendations until there is sufficient time. The PSSR should check that the recommendations have, in fact, been closed out properly. 

An audit check performed prior to equipment operation to ensure that adequate Process Safety Management (PSM) activities have been performed. The check should verify that (1) construction and equipment are satisfactory, (2) procedures are available and adequate, (3) a Process Hazard Analysis (PHA) has been undertaken and recommendations resolved, and (4) the employees are trained. It is part of the requirements of the PSM program outlined in the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.119. 

Once all what-if analysis questions have been asked and answered along with all completed HAZOP studies of system components, a final report should be written to document all findings and recommendations. In the chemical industry (in the United States), this report is normally referred to as a process hazard analysis. This report is required under both OSHA and EPA regulations for facilities that handle or contain certain chemical commodities at certain defined quantity thresholds. However, when HAZOP studies and what-if analyses are used in general industry application, documentation of the results can be included in a written report along with any other system safety analyses that may have been performed (as described in previous chapters). If the HAZOP and what-if exercises were conducted as standalone analyses, then a final written report should be... 

OSHA process safety management regulations require process hazard analysis. 

Overall, then, the only additional RMP requirement for plants already covered by the OSHA process safety management regulation is the hazard assessment (including offsite consequence analyses of worst-case and non-worst-case accidental release scenarios). This hazard assessment must not be confused with the process hazard analysis (PHA). The hazard assessment is a study of what will happen in the event of an accidental release and usually includes, for exanple, air dispersion simulations. The PHA (e.g., HAZOP) studies the hazards present in the process and seeks to minimize them through redesign or modifications to operating procedures. 

Under the Process Hazard Analysis requirement of the Process Safety Management of Highly Hazardous Chemicals regulation (29 CFR 1910.119), employers must conplete such an analysis of all covered processes using one or more of the following techniques ... 

This example shows cradle-to-grave documentation for each SIF. This documentation pedigree gives auditors and plant personnel the means to track the SIF through the safety lifecycle phases back to the process hazards analysis (PHA) that created it. Each SIF is clearly identified in each document to facilitate tracking between lifecycle phases. A vital part of safety is the ability to demonstrate to others (e.g., auditors, regulators, insurance companies) that the risk reduction provided by each SIF is adequate. 

For chemical faciUties in the United States, hazard analysis is not an option if inventories of hazardous chemicals are maintained in amounts greater than the threshold quantities specified by the Occupational Safety and Health Administration (OSHA) regulation 1910.119. Many faciUties are finding that hazard analysis has many benefits. The process or procedure often works better, the quaUty of the product is improved, the process experiences less down time, and the employees feel more comfortable in the work environment after a hazard analysis has been completed. 

Experimental analysis involves the use of thermal hazard analysis tests to verify the results of screening as well as to identify reaction rates and kinetics. The goal of this level of testing is to provide additional information by which the materials and processes may be characterized. The decision on the type of experimental analysis that should be undertaken is dependent on a number of factors, including perceived hazard, planned pilot plant scale, sample availability, regulations, equipment availability, etc. 

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