THOUGHTS ON IMPROVING PROCESS HAZARD ASSESSMENTS PHA / HAZOP

I happened to be doing some searching with the trusty Google search engine the other day and found an interesting paper presented at the Global Congress on Process Safety 2017. There were so many facts and leanings that It was worth pulling out a few extracts to share with our regular readers. The Authors are clearly superstars with extensive experience when it comes to Risk Assessment methodologies and Hazard Assessments.

The paper I found on their web site was called “Recipe for Complete Hazard Analysis – Especially Addressing the Key Demands from US CSB” written by Revonda Tew and William Bridges of the Process Improvement Institute. Here is a link to the paper from the Process Improvement Institute.

According to the abstract, the results are based on thousands of units sized PHA’s performed or managed by the authors. I have put a link to the company website if you want to access the content or reach out to them to conduct consulting services.

As you may know I am a lifelong practitioner in Risk Assessment so I truly do respect the above authors’ work that I have been reviewing.

Below are some interesting factoid extracted from the paper that are worth noting.

“80% of PHAs performed today do not comply with the current interpretations by US OSHA, much less industry practices.”

“Most PHAs address less than 10% of the Hazards during startup, shutdown, and online maintenance.”

“Less than 30% address damage mechanisms such as corrosion, erosion, external impact, external stresses, vibration ext.”

The authors point out some of the critical aspects of a fully compliant (excellent) PHA that include:

• “Excellent team leadership and PHA scribe that are fully competent in all aspects of a Best Practice PHA, including how to efficiently lead and document the PHA.
• The most experienced and knowledgeable team members available from operators, operations engineers, and others as needed.
• Up-to-date process safety information and access to underlying details, as needed.
• Up-to-date, clear, and accurate operating procedures.
• Thorough understanding and coverage of facility siting issues and human factors.”

Based on my 40 plus years of experience, I can only say that I agree with this entire list. If I were to add one of my own observations, it would be this one as well.

• All mitigative and preventive actions taken related to high risk incidents need to be followed up in a timely manner and monitored appropriately over time to ensure the actions taken do truly control the potential causes of such incident events.

Getting the PHA/HAZOP meetings done correctly and efficiently is good, but getting all the actions completed after the meeting is over is critical. Failure to take appropriate actions following any risk analysis renders that risk study as wasted time and leaves the company in a state of unnecessary liability.

The Authors bring up this important topic in the paper as well.

“From an informal survey of more than 100 companies, most do not currently perform process hazard evaluations of procedures, although many do perform some type of job safety analysis (JSA).” He goes on to point out that “the purpose of a hazard evaluation is not to ensure the procedures are accurate and acceptable, but instead, to evaluate the accident scenarios if the procedures are not followed.”

“Many companies do not perform a thorough analysis of the risk for startup, shutdown, and on-line maintenance modes of operation; the reason normally given is that the analysis of these modes of operation takes “too long.” Yet, actually, the hazard evaluation of the normal mode is taking too long, and so the organization feels it has no time left for the analysis of procedures for startup and shutdown modes of operation. But, if these hazard evaluations for the normal mode of operation are optimized (such as using rules presented elsewhere23), the organization will have time for thoroughly analyzing the non-routine modes (typically discontinuous modes) of operation, and the organization will still have a net savings overall!”

Their paper also brings up another interesting factoid that all risk managers should have at their disposal when defending investment in hazard analysis for their business.

“70-80% of catastrophic accidents occur during non-routine modes of operation.”

This factoid was sourced by the authors from a paper titled. “Necessity of Performing Hazard Evaluations (PHAs) of Non-Normal Modes of Operation (Startup, Shutdown, & Online Maintenance)”, W. Bridges and Mike Marshall (US OSHA), 18th Annual International Symposium, Mary Kay-O-Connor Process Safety Center, College Station, TX, October 2015 and 12th Global Congress on Process Safety, April, 2016.

You may want to download the full paper from the authors if you are responsible for your company’s process safety program.

I am always interested in learning more about how our reading guests and users are dealing with the core issue of not having enough time to complete all the required modes of operation in a PHA/HAZOP. I am sure there are things we could (or already have done) to our software to help better streamline process. However, if you have any additional thoughts about where you see the biggest bottlenecks or have any other comments, I invite you to please reach out to me at pmainprize@sharrix.com.