PHA Revalidation FAQs

Why should I revalidate my PHAs?

US OSHA process safety management (PSM) regulation (29 CFR 1910.119) requires that PHAs be updated and revalidated every five years. US EPA risk management program (RMP) rule has similar provisions and adds the requirement of identifying process releases that could have offsite impacts. In addition, chemical and petroleum industry standards and most internal company standards require hazard reviews to be kept up to date.

How should I revalidate my PHAs?

The decision as to the most appropriate revalidation approach for your facility depends upon several factors:

What was the quality of the initial PHAs?
How extensive have changes to the process been?
How effective has your MOC program been?

The answers to these questions will tell you whether you need a Redo, Retrofit, Update, or Revalidation of your facility's PHAs. These different types of revalidation are defined below:

a) Redo: Perform a complete, new PHA that meets the requirements of U.S. 29 CFR 1910.119(e) and 40 CFR 68.67 or similar company standard.

b) Retrofit: Perform a hazard evaluation of process sections to augment a previous PHA, to address a specific issue, or to address potential offsite consequences under 40 CFR 68.67.

c) Update: Modify a PHA to account for changes that have been introduced or incidents that have occurred since the previous analysis.

d) Revalidation: Confirm that a PHA accurately reflects the process hazards given the current equipment configuration, process operations, staffing and surroundings, and that the analysis meets the requirements of 29 CFR 1910.119(e) and 40 CFR 68.67 or similar company standard.

Who should be on my PHA revalidation team?

OSHA and EPA require that your PHA revalidation team have the same range of expertise as the team that performed the initial PHAs, but the team members need not be the same team members as the initial PHA.

For more information...

Contact ABS Consulting directly via e-mail, telephone or fax...

info@absconsulting.com | Tel: 1-281-673-2800 | Fax: 1-281-673-2950

OR submit a question or request and we'll get back to you...