2012 Spring Meeting & 8th Global Congress on Process Safety
(40c) Avoiding Common PHA Mistakes
Author
OSHA's National Emphasis Program (NEP) on refineries has
concluded. The two most cited
elements of the Process Safety Management standard (PSM - 1910.119) in the NEP
were Mechanical Integrity and Process Hazard Analysis (PHA).[1]
This session will focus on common problems in PHA and how to
avoid them. Although OSHA's data
and citations are not commonly available, the problems identified in this
session have been collected from interviews with OSHA compliance agents, from
conversations with refineries that have been audited, and from personal
observations. The personal
observations are sourced from the past eleven years of auditing refineries,
chemical plants, pipelines, and pharmaceutical companies.
In addition to discussing PHA problems that could result in
regulatory citations, the session will additionally offer a selection of best
practices from a variety of industries.
This "Back to Basics" session will assume that
attendees are familiar with the regulatory requirements of PSM pertaining to
PHA.
Glenn Young, C.S.P.
[1] Information
from Region VI OSHA Area Director Dorinda Folse - quoted from the September ASSE meeting, Baton
Rouge, LA