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OSHA Process Hazard Analysis Revalidation

The Challenge

The traditional approach to updating and revalidating a Process Hazard Aanalysis (PHA) each five years as required by OSHA in 29 CFR 1920.119(e)(6) is to redo the entire PHA using an OSHA approved analysis method such as Hazop, What-If/Checklist, etc. Performing a new PHA may be appropriate where the original PHA was improperly performed or where process changes made subsequent to the original analysis were not properly evaluated. Repeating the complete PHA requires finding a block of time for 5-10 members of a team to get together to perform the tedious Process Hazard Analyis. The analysis itself could take several days or perhaps weeks to perform.

The Solution

Because most original PHA's were adequately done and only need revalidation, Universal Dynamics has developed a unique PHA revalidation procedure that utilizes the existing investment in the original PHA and the plant's Management of Change procedure to minimize the revalidation cost and manpower requirements. Our alternative revalidation approach can be accomplished in significantly less time and does not require our client's personnel to spend several days performing a complete PHA that may be mostly redundant. This revalidation approach saves time, energy, and minimizes the impact on the schedules of key plant personnel provided that the facility has a relatively complete original PHA which only requires revalidation to meet the intent of the OSHA regulations*.

* "At least each five (5) years after completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements of (e)(4) of this section, to assure that the process hazard analysis is consistent with the current process." 29CFR 1910.119(3)(6)