Revalidating Process Hazard Analyses

The foundation of any successful process safety program is a current set of process hazard analyses (PHAs) for each of its processes. Revalidating PHAs to keep them up to date and applicable is a must. This book is derived from the experience of many companies in the chemical and hydrocarbon processing industries, and presents demonstrated, concise, and common sense approaches for a resource-effective revalidation of PHAs. It includes flowcharts, checklists, and worksheets that provide invaluable assistance to the revalidation process.

Walter L. Frank is the author of Revalidating Process Hazard Analyses, published by Wiley.

David K. Whittle is the author of Revalidating Process Hazard Analyses, published by Wiley.

Preface

ix

Acknowledgments

xi

Glossary

xiii

Acronyms and Abbreviations

xvii

Introduction

1

(1)

Why Was This Book Written?

1

(1)

Scope of This Book

2

(1)

The CCPS Workshop

3

(1)

How This Book Is Organized

3

(2)

Refresher on the Basics

5

(6)

What a PHA Is Intended to Accomplish

5

(1)

Brief Review of the More Common PHA Methodologies

6

(3)

PHA Team Make-Up

9

(2)

Revalidation---What Is It?

11

(8)

The Reason for Revalidation

11

(2)

Revalidation Objective

13

(1)

Revalidation Concept

13

(1)

Establishing the Revalidation Schedule

14

(2)

The Role of a Revalidation Procedure

16

(3)

Preparing for the Revalidation Study

19

(14)

Preplan the Revalidation

19

(4)

Establishing the Scope of the Revalidation

19

(1)

Selection of Team Members

20

(2)

Scheduling---Estimating Time and Resources

22

(1)

Identify, Collect, and Prepare Needed Information

23

(4)

Determining Information Requirements

24

(1)

Distribution of Information

24

(3)

Review and Analyze Information

27

(6)

Prior PHA Report(s) and Related Documentation

27

(1)

Resolution Completion Report for Prior PHA Recommendations

28

(1)

MOC and PSSR Documentation

29

(1)

PSM System Audit Results

30

(1)

Incident and Near-Miss Reports

30

(1)

Piping and Instrument Diagrams (P&IDs)

31

(1)

Operating Procedures

31

(2)

Evaluating the Prior PHA Study

33

(10)

Evaluation of the PHA with Respect to Essential Criteria

34

(3)

PHA Rigor

35

(1)

Methodology Used

36

(1)

Team Make-Up

36

(1)

Documentation

36

(1)

Drawing the Conclusions

37

(1)

Evaluation of PHA Quality and Completeness

37

(2)

Other Considerations

39

(1)

Common Problems with PHAs

39

(4)

Identifying Changes That Have Occurred Since the Prior PHA

43

(8)

Logging the Identified Changes

43

(1)

Documented and Controlled Changes

44

(3)

MOC and PSSR Review

44

(2)

P&ID Comparison

46

(1)

Procedure Reviews

46

(1)

PHA and Incident Investigation Recommendations

46

(1)

Undocumented and Uncontrolled Changes

47

(4)

Interviews of Facility Personnel

47

(1)

Maintenance Records

48

(1)

Purchase Specifications and Records

49

(1)

Incident Investigation Reports

49

(1)

PSM Program Audits

49

(2)

Identifying an Appropriate Revalidation Methodology

51

(8)

Revalidation Options

51

(4)

Update and Revalidate

51

(1)

Retrofit, Update, and Revalidate

52

(1)

Redo

53

(2)

Selecting the Revalidation Options

55

(4)

Conducting the Revalidation Study Sessions

59

(6)

Team Training

59

(1)

Application of Revalidation Methodology

60

(1)

Special Topics

60

(5)

Staying Productive

60

(1)

Facility (or Stationary Source) Siting

61

(1)

Human Factors

61

(1)

Wrap-Up Discussions

62

(3)

Documenting the Revalidation Study

65

(4)

Documentation Approaches

65

(2)

Report and Its Content

67

(1)

Recommendation Follow-Up

67

(1)

Records Retention and Distribution

68

(1)

Appendix A Federal Regulatory Requirements

69

(6)

Appendix B Essential Criteria Checklist

75

(2)

Appendix C PHA Quality and Completeness Checklist

77

(8)

Appendix D Example Change Summary Worksheet

85

(2)

Appendix E Facility and Process Modification Checklist

87

(6)

Appendix F Facility and Stationary Source Siting Checklist

93

(10)

Appendix G Human Factors Checklist

103

(8)

Bibliography

111

(2)

Index

113

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Revalidating Process Hazard Analyses

Summary

Author Biography

Table of Contents

Supplemental Materials