(40i) Revalidating a Hierarchy of Hazard Controls Analysis

Analyses other than a process hazard analysis (PHA) may need to be revalidated periodically. For example, a Hierarchy of Hazard Controls Analysis (HCA) is required to be "updated and revalidated" by the California OSHA (CalOSHA) Process Safety Management (PSM) for Petroleum Refineries and "updated" by the California Accidental Release Prevention (CalARP) Program 4 requirements every 5 years.

The CCPS book Guidelines for Revalidating a Process Hazards Analysis, 2nd Edition, published in 2022 outlines a method for using the Redo and Update approaches for revalidating analyses that are "complementary" to a PHA, such as an HCA or a Dust Hazard Analysis (DHA).

This poster will lay out a simple and effective procedure to revalidate an analysis (e.g., HCA) that has already been performed by using the same steps as a PHA revalidation: (1) Evaluate the prior analysis, (2) Evaluate operating experience since the prior analysis, (3) Select an appropriate revalidation approach, (4) Prepare for and conduct the meetings, and (5) Document the results.