A PHA team must have the following expertise:

  • engineering and process operations;
  • experience and knowledge specific to the process being evaluated; and
  • a facilitator (knowledgeable in the specific PHA methodology being used)

Employers must have a written plan to include employees and their representatives on the conduct and development of PHAs. 29 CFR 1910.119(c) and 40 CFR 68.83(b). Employee participation is to be a two-way dialog with employees using their experience to participate and in development of PHA recommendations. When inspecting a site, OSHA and EPA usually look for evidence of employee participate by asking for the names of participating employees and interviewing those employees. OSHA intended for the term “their representatives” to be read broadly, and include union representatives, or in the case of a non-union plant, any person designated by employees. See OSHA guidance, CPL 02-02-045.

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