PHA Revalidation

PHA Revalidation is the re-examination of a PHA to make sure that it is consistent with the current process, as well as the identification of known process hazards and checks that engineering and administrative safeguards are adequate to control the hazards of the process.

Typical Tasks Associated with a PHA Revalidation

As part of a PHA Revalidation, you must perform a hazard evaluation of all known modifications made to the process since the initial PHAs to confirm that any hazards associated with the modifications have been incorporated into the current PHA results. Note: if the management of change (MOC) program for the process was not in place and/or ineffective for some period of time after the initial PHAs or if there are an excessive number of MOCs since the initial PHAs, it may be more prudent and/or efficient to redo the PHAs instead.

This is necessary to make sure that the updated and revalidated PHAs reflect all hazards of the current process.

Once the hazard evaluation has been completed, you must review incident investigation reports made since the initial PHAs. You should also review the status of recommendations from the initial PHAs, especially any unaddressed recommendations. These reviews accompany any revalidation and are necessary to update the initial PHAs.

After the reviews have been made, your organization should perform or upgrade the evaluation of human factors and/or facility/stationary source siting issues using checklists. The evaluation should focus specifically on how process modifications may have affected these issues.

Following the evaluation, your operations' personnel should discuss the hazards involved with non-routine operating modes such as startup, shutdown, maintenance and sampling in the process unit to help identify procedural and/or equipment deficiencies that could contribute to human errors. This could involve a detailed hazard review of selected written procedures for the process, or at a minimum, using these modes of operation as guide words in the hazard analysis.

The evaluation of human factors involved and the hazard discussion are enhancements to the initial PHAs. If the initial PHAs were completed before regulation 29 CFR 1910.119 was issued or shortly thereafter, the PHAs may not have adequately addressed these issues. Performing these two tasks will help illustrate compliance with the PHA requirements in regulations 29 CFR 1910.119 and 40 CFR 68.

Finally, you should discuss process releases from each process node to identify releases that could have offsite impacts, including impacts to the public or the environment as defined by EPA regulation 40 CFR 68. This provides a revalidated PHA that also meets the requirements of regulation 40 CFR 68.

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