How to effectively revalidate PHAs
- JBF Associates, Inc., Knoxville, TN (United States)
Under OSHA process safety management (PSM) standard 29 CFR 1910.119, process hazard analyses (PHAs) must be updated and revalidated at least every five years. This rule was promulgated in 1992; however, many operating companies began PHA programs as early as 1990. Now these initial PHAs must be revalidated due to the time limit. Because OSHA 1910.119 only gives guidance, hydrocarbon processing industry companies can select the revalidation method to use and have several options: redo the PHA as if it were the initial one; retrofit, update and revalidate the PHA by concentrating on deficiencies in the original analysis and incorporating process changes; and update and revalidate the original PHA for process changes only. Using guidelines and the evaluation flow diagram, companies can cost-effectively decide how much rework is needed to maintain PSM compliance. The paper discusses regulatory requirements, revalidation approaches, collect supporting documentation, initial/previous PHA quality, operating experience, conducting and documenting revalidation analyses, and documentation.
- OSTI ID:
- 392545
- Journal Information:
- Hydrocarbon Processing, Vol. 75, Issue 10; Other Information: PBD: Oct 1996
- Country of Publication:
- United States
- Language:
- English
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