Operating companies covered by OSHA’s Process Safety Management (PSM) standard or EPA’s Risk Management Program (RMP) rule are required to revalidate their Process Hazard Analysis (PHA) every five years. Very frequently, process hazard analysis (PHA) teams encounter frustrating challenges, including: Identification of a hazard introduced by a process change, identification of a hazard similar to a recent incident that was either overlooked in the previous PHA or deemed to have adequate protection, and inadequate documentation from the previous PHA. Clearly, PHA revalidation is an essential and critical activity. However, how and when it is performed determines if it will be effective in preventing incidents. This paper discusses the merits of a new approach geared towards increasing the effectiveness of PHAs. Called Continuous PHA Revalidation, the new approach may be summarized by asking a simple question: Why not revalidate your existing PHA every time a change is made or every time an incident investigation is completed?
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