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PHA

Blog, Data Management, PHA

How Better Access to PHA Data Can Inform Your MOC Process

© Vanderbilt University Center for Teaching

In Bloom’s Taxonomy, “evaluation” is the fifth of six levels. Learners progress from remembering, to understanding, to applying, analyzing and then evaluating and finally creating.

One of the most important “evaluating” exercises in Process Safety Management (PSM) is the Process Hazard Analysis (PHA).

In a PHA, a group of people with expertise in the process (operators, engineers, etc.) gather to look at all the equipment and chemistry and technology involved.

They detail out each possible hazard, cause, consequence and safeguard. They review the risks, make recommendations, and put all of this information into a report.

Re-Evaluating in Process Safety

When you re-evaluate something, it’s typically done with an eye towards any changes or new information.

In PSM, we re-evaluate the hazards when we make a change through the management of change (MOC) process or when there has been an incident and we want to see what went wrong and if we missed something in the first evaluation of the hazard.

When you want to evaluate something again, it would seem natural to look at the original evaluation.

In significant incident investigations, the PHA report is often pulled up to determine if something was missed or a recommendation wasn’t completed.

But during the course of an MOC, it is very rare for the original PHA to be referenced.

Even if the project involves significant change and generates its own PHA, it is not always standard practice to reference the original unit PHA.

One reason for this is the great complexity of the information in a PHA and the challenges in finding a specific area.

In short, the PHA details aren’t always easily accessible.

And as I said, it’s not a standard practice.  Most MOC procedures I’m familiar with do not include a checkbox for looking at the original PHA.

In my many years as a process engineer, I was never advised to look at the PHA for the unit when doing a change. We simply did our own mini-PHA with the group of engineers and operators on hand.

PHA Data Can Be a Valuable Resource

But what about the great level of time and expertise that had already been invested in the most recent PHA? What if something we changed had been counted on for a safeguard? Maybe we caught it in our project group, but what if we didn’t?

There are many advantages to making PHA results and comments more structured and searchable.

One of those is the opportunity for engineers and operators to easily reference nodes and sections of a unit and review the hazards when a change is being proposed and reviewed.

It is one more way we can all have the best information on hand to make wise and safe decisions.


Our Managing Partner Patrick Nonhof presented a webinar on “Can PHA Be Big Data”. He discusses applicable, practical ways to make your PHA data more useful by addressing the barriers to its usability – lack of structure and lack of accessibility. The possibilities for data analysis and continual value-add on your PHA data is an untapped resource at many facilities. Let us help you realize that potential.

Read More from the Five PSM Mindsets™ Series:

This series is based on the concept of the Five PSM Mindsets™ – a unique way to apply OSHA’s 14 PSM elements to your PSM program. Watch this on-demand webinar from Sarah McDuffee for a better understanding of the Five PSM Mindsets™ and how adopting them can create a better process safety culture in your facility.
Sarah McDuffee
About the Author
Sarah McDuffee
Sarah McDuffee joined Provenance Consulting in 2015 as Training Program Coordinator, creating internal and external training courses for industry clients on various Process Safety Management topics. Her background includes 19 years of experience in the refining/chemical industry. She has a B.S. in Chemical Engineering from Montana State University.  Her 11 years with a major refining company included project design, process unit support and distillation consulting roles.

She completed her Masters in Adult Education and Training with Colorado State University in 2011 while working for Northern Oklahoma College as an engineering instructor for 5 years. During that time, Sarah also served as Program Director for the Process Technology program for four years, partnering with industry on curriculum, recruiting and placement.

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How to Protect Your Ship from Process Safety Hazards

In Star Trek, the ship is protected by a force field called a “shield”.  When under attack, the tactical officer will call out the status of the shield’s integrity, e.g. “shields at 70%, Captain.”  When shields are down to 10%, you know that a breach is imminent unless they retreat or find a way to defeat their attacker.

In a refinery or chemical plant, there is no one calling out the integrity of our protection systems and procedures every few minutes.

But OSHA has specified three specific process safety elements that are critical to Protect Against the Hazards (one of the Five PSM Mindets™) – Pre-Startup Safety Reviews, Mechanical Integrity, and Hot Work Permits.

Taking Action to Prevent Disaster

Once we’ve identified the hazards, it’s time to do something about it. We’ve seen where danger may strike, so we go to the possible sources. We anticipate what could go wrong and prepare for it.

  • We put procedures in place to create consistency and avoid mistakes. But are the procedures being followed? 
  • We add alarms and limits to alert us to known unsafe conditions. Will the appropriate alarms overwhelm the operator in the event of an emergency? 
  • We install systems such as relief valves and automatic shutdowns to react as quickly as physically possible if a dangerous limit is exceeded. Are the safety relief devices and shutdown systems being maintained according to industry standards?  What about the mechanical integrity of the pipes, pumps, or vessels? 

In a process hazard analysis (PHA), safeguards and layers of protection are identified and counted on.  And in our industry, there is a great deal of focus on mechanical integrity and maintaining safety instrumented systems.

The Shield Doesn’t Replace the Crew

In a successful process safety culture, the success or failure of the facility is the responsibility of everyone together – like the crew on Star Trek.

If you are going to help ensure the shields are at maximum strength, here are a few places to start:

  • First, know your enemy – become familiar with the hazards that have been identified and communicated to you.
  • Get to know what the protection layers are for the areas you work in.
  • When there are safe work practices and procedures in place, follow them closely. When you know the “why” behind the procedure, you can be on the lookout for any gaps or concerns.

The safety of a star ship isn’t just dependent on its shield. It depends upon each crew member doing their part and working as a team.

The safety of a facility isn’t just based on the safeguards put in place, but upon each person inside the gate doing their part.

You are more than helping maintain the “shield” – YOU are an integral part of the shield preventing catastrophe so that we may all “live long and prosper”.

Read More from the Five PSM Mindsets™ Series:

This series is based on the concept of the Five PSM Mindsets™ – a unique way to apply OSHA’s 14 PSM elements to your PSM program. Watch this on-demand webinar from Sarah McDuffee for a better understanding of the Five PSM Mindsets™ and how adopting them can create a better process safety culture in your facility.
Sarah McDuffee
About the Author
Sarah McDuffee
Sarah McDuffee joined Provenance Consulting in 2015 as Training Program Coordinator, creating internal and external training courses for industry clients on various Process Safety Management topics. Her background includes 19 years of experience in the refining/chemical industry. She has a B.S. in Chemical Engineering from Montana State University.  Her 11 years with a major refining company included project design, process unit support and distillation consulting roles.

She completed her Masters in Adult Education and Training with Colorado State University in 2011 while working for Northern Oklahoma College as an engineering instructor for 5 years. During that time, Sarah also served as Program Director for the Process Technology program for four years, partnering with industry on curriculum, recruiting and placement.

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The Importance of Operating Procedures & How to Use Them Effectively

Could your facility be under-utilizing your operating procedures? Find out how to use them beyond day-to-day operations.

This 60-minute sponsored webinar starts off by looking at why operating procedures are essential to your safety and efficiency, OSHA requirements related to their content and generation and common mistakes made in the process. You’ll then go on to consider the ways operating procedures can be used beyond the day to day. Learn how operating procedures are a vital part of your PHAs and closely linked to PSI. In addition, discover effective methods for maintaining, storing and accessing operating procedures. By the end of the webinar, you’ll have a better understanding of operating procedures and how to use them more effectively in your facility.

Learn more about our PHA Services

Presenter

Justin Phillips, P.E.

Justin Phillips has over eight years of onshore and offshore oil & gas process engineering and project execution experience. His technical experience includes process design with specialty in flare and relief systems.

Justin is the Relief Systems Line of Service Manager at Provenance Consulting, LLC. He holds a B.S. in Chemical Engineering from Texas A&M University in College Station, Texas and is a Licensed Professional Engineer in the State of Texas.

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