Why Is Process Hazard Analysis (PHA) So Challenging?

January 7, 2025

Tackle the requirements of Process Hazard Analysis (PHA) by leveraging the user-friendly FACILEX® PSM suite of solutions. A fully integrated approach for facilities to maintain current PSI, and ensure evergreen PHAs and structured processes to ensure follow-up actions are closed-out and the evidence recorded.

Process Hazard Analysis (PHA) is a cornerstone of process safety management, aimed at identifying, evaluating, and controlling risks associated with hazardous processes. However, conducting an effective PHA is a complex and resource-intensive task. It requires accurate information, skilled professionals, and a systematic approach to ensure a thorough analysis and actionable outcomes.

Key Challenges in Conducting a PHA

1. Understanding the Current Plant Configuration

Misunderstandings or outdated views of the plant’s process safety information (PSI) can lead to an incomplete hazard analysis and missed risks. Accurate assessment depends on a clear understanding of the facility’s current plant configuration, including:

Equipment layout
Operational processes
Existing safeguards

2. Accurate and Up to Date Process Safety Information (PSI)

PHAs rely heavily on PSI such as piping and instrumentation diagrams (P&IDs), material safety data, and operating conditions. Challenges arise when PSI is outdated due to facility changes that are not reflected in approved and released documents.

3. Specialized Software Requirements

Modern PHAs often require the use of dedicated software to facilitate analysis and manage complex data. Challenges include:

Selecting software that aligns with the facility’s requirements
Ensuring proper training for team members to effectively use the software
Managing secure storage and easy access to PHA project data

4. Dependence on Qualified Professionals

PHAs should be conducted by experienced process safety professionals with the applicable qualifications and expertise. Finding and retaining skilled professionals can be a significant challenge for PSM covered facilities.

5. Managing PHA Recommendations

A key outcome of PHAs is a list of recommendations to mitigate identified risks. Failure to follow up on recommendations undermines the entire analysis process. To ensure safety and regulatory compliance facilities must ensure PHA recommendations are:

Recorded: Properly documented for review and follow-up
Followed-Up: Monitored to confirm actions are taken
Closed Out: Verified as complete with clear evidence

6. Revalidation Requirements

OSHA mandates that PHA projects be revalidated every five years to ensure they remain relevant to current operations. Challenges include:

Keeping track of revalidation schedules
Allocating resources for regular updates and reviews
Adapting to new operational changes or regulatory requirements during revalidation

Best Practices for Overcoming PHA Challenges

Ensure the plant configuration is known. Establish strict controls to ensure PSI is updated immediately following any process or equipment changes.
Use robust PHA software. FACILEX^® PHA delivers user-friendly analysis and securely manages project data.
Build a skilled PHA team. Train internal staff and collaborate with external experts to maintain a pool of qualified professionals.
Ensure close-out of PHA follow-up action items. FACILEX^® PHA delivers task assignments, implementation, and close-out action tracking and audit trail records.
Plan for regular PHA revalidations. Schedule PHA revalidations well in advance and incorporate them into the facility’s overall safety management plan.

Conclusion

Conducting an effective Process Hazard Analysis is no small feat, given the challenges of managing accurate information, skilled personnel, and actionable outcomes. However, with a proactive approach to maintaining current PSI, leveraging user-friendly PHA software such as FACILEX^® PHA, and adhering to structured processes, organizations can overcome these obstacles. By addressing PHA challenges head-on, facilities can not only achieve compliance but also foster a safer and more reliable operational environment.

Gateway Group

Gateway Consulting Group has been a leader in information management solutions for over 30 years, helping businesses navigate complex challenges with a blend of cutting-edge technology and expert consulting. By tailoring solutions to each client's needs, Gateway ensures efficiency, compliance, and streamlined business processes. With decades of experience, Gateway continues to deliver best-in-class strategies that optimize information management, combining innovative tools with a deep understanding of industry requirements.

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