Determine the complexity of the Process Hazards Analysis (PHA) and the implementation schedule.
Define the analysis tools that are acceptable for the complexity of the process.
Minimally, the PHA should cover:
Process Hazards
Previous Incidents
Engineering & Administrative Controls
Consequences of Failure of Engineering & Administrative Controls
Facility Siting
Human Factors.
Outline team requirements.
Report findings, recommendations, implementation, and documentation.
Update/reevaluate process with PHA team every 5 years.
Be sure to maintain all associated PHA documentation for process life.
SMS Will:
Perform preliminary facility and process assessment.
Assist customer in prioritization of evaluation for hazardous processes.
Serve as PHA team leader to implement HERCŪ hazards analysis techniques for identification of hazards consistent with process complexity.
Recommend in-process energies and material response testing.
Document the PHA findings/recommendations.
Assist in establishing a system to handle the tracking of recommendations.
Document the corrective action resulting from the PHA findings/recommendations.
Participate with PHA team to periodically update/reevaluate process.
Assist in the establishment of a PHA documentation access and control system.
Client Will:
Set priorities for process evaluations.
Be responsible for the actual implementation of PHA findings/recommendations.
Be responsible for maintaining associated PHA information for the life of the process.
EPA 40 CFR Part 68 Elements
