Process Safety Management of Highly Hazardous & Explosive Chemicals

Process Hazard Analysis (PHAs) & Management of Change

Process Hazard Analysis (PHA)

1910.119(e)

Process Hazard Analysis (PHAs)

Arguably the Most Difficult Part of Performing the Standard Performed by Your PSM Team Takes Significant Time & Effort

Remember

Block Diagram

P&ID

Process Equipment Numbering

You Developed a List of Equipment Elements

Choose a PHA Process Method

Must select a process hazard analysis (PHA) method
What-If;

Checklist;
What-If/Checklist;

Hazard and Operability Study (HAZOP);

Failure Mode and Effects Analysis (FMEA); Fault Tree Analysis

The PHA Must Address:

Equipment in the process Hazards of the process Identification of previous incidents Engineering and administrative controls Consequences of failure Facility sitting Human factors Qualitative evaluation of S and H effects Consequences of deviation Steps required to correct or avoid deviation

Lets Choose the What If Method

In a What If hazard analysis, brainstorming techniques, in the form of What If questions are used to identify possible deviations and weaknesses in design. Once identified, these concerns and their potential consequences are evaluated for risk.

PHA What if Method

PHA Risk Analysis

PHA Risk Analysis

Process Hazard Analysis

A PHA Process Must be Performed on Each Element of the Covered Process: A PHA From Block Diagram to P&ID to Every Equipment Element to Determine What Might Happen if an Element of the Covered Process Fails

Continue the PHA

Continue the PHA Process UNTIL

Continue the PHA

All Events

Continue the PHA

All Deviations

Continue the PHA

All Causes

Continue the PHA

All Consequences

Continue the PHA

All Safeguards

Continue the PHA

All Risk Levels

Continue the PHA

All Recommendations

Continue the PHA

Are Completed for 1. Every Element of 2. Every P&ID of 3. Every Block Diagram Section 4. Of the Entire Covered Process 5. Is Complete

Continue the PHA

This Process Might Entail Thousands of Covered Process Elements and Take Years to Complete

Establish a Project Tracking Method for all PHA Activities

What Do We Do With the PHAs Developed?

Using the Risk Column, Begin:

Reviewing Defense Designs Warning/Alarms to Warn of Deviations Relief Systems Ventilations Systems

What Do We Do With the PHAs Developed?

With Those Analysis Complete:

Begin Implementation of Engineering Controls to Minimize Potential of Releases

Management of Change
1910.119(I)

What if Our PHAs Reveal the Need to Change Something In our System to Minimize the Potential for Release
We Must Use Management of Change (MOC)

Management of Change Why?

Many of the catastrophic accidents over the past few decades can be traced, in large part, to a management of change system that was not in place or was not functional (e.g., Flixborough, Bhopal).

Management of Change (MOC)We Must

Explain the purpose of MOC Set the provisions to be considered for temporary change Define and give example of change in equipment that requires MOC Define and give examples of changes in procedures when need Define and give examples of change in process technology

Management of Change (MOC)We Must

Define and give example of a major change Define and give example of a minor change Define and give examples of "replacement in kind Describe and list the procedures required for initiating and completing a MOC

What Do We Do With the PHAs Developed?

Any Changes in Defense Designs, or System Engineering will Require Management of Change

P&ID Equipment Lists Inspection/Testing/ Maintenance Procedures PHAs

Management of Change (MOC)

MOC procedure should ensure that equipment and procedures are returned to their original conditions at the end of a temporary change MOC forms/clearance sheets are acceptable control methods of tracking changes More complex changes require a more "formal hazard evaluation" than simple changes (PHA not specifically mentioned).

Management of Change (MOC) - Pre-Modification Issues

Check codes, standards, internal engineering specifications Complete design review Perform reactivity testing for new substances Add materials to TSCA/SARA inventories Complete safety and health impact review Comply with safety and loss prevention requirements

Management of Change (MOC) - Pre-Modification Issues

Complete maintenance review/revise spare parts list Evaluate change against vent, relief, and flare capability Complete industrial hygiene review Review change against existing environmental permits Obtain required approvals

Management of Change (MOC) - Post-Modification Issues

Completed Process Safety Systems Review (PSSR) Completed training on change for affected employees SOPs marked-up P&IDs, PFDs, plot plans and other affected Process Safety Information (PSI) marked-up Training program modifications identified Preventive maintenance program modifications identified

Management of Change

Must Have a Method for Request, Tracking, Completion and Other Systems Affected.

Process Hazard Analysis Summary

The Process Hazard Analysis is the Backbone of the Process Safety Management Program. It Provides the Structure Upon Which PSM is Built It Makes Available Pertinent Data & Safety Information to Design an Effective PSM Safety Program

Management of Change Summary

We must establish and implement written procedures to manage changes except "replacements in kind" for a covered process. If a Change in Design or Components is Required, Management of Change Must be Employed, Tracked, and Analyzed. All PHAs, P&IDs & Required Procedures Must be Revised Work-site employees and contract employers must be informed and trained on the changes prior to start-up.

PSM Documentation Technology Use

Consider the Use of Technology to:

Perform Document Track Adjust Maintain

The PSM Program

Whats Next?
In the Next Session, we will Cover the Standard Operating Procedures and Safety Programs That Must Be Developed Based on the Results of the PHAs