Process Hazard Analysis

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By R. Lee Vail, P.E., Ph.D.

At the very end of 2016, the Fifth Circuit Court of Appeals vacated two Occupational Safety and Health Administration (“OSHA”) citations against an employer that allegedly failed to timely resolve open findings and recommendations from Process Hazard Analysis (PHA). The 2008 citation related to multiple PHAs that occurred over

The United States Environmental Protection Agency in Washington DC. (Photo by: Loop Images/UIG via Getty Images)

By Lee Vail

On March 14, 2016, Environmental Protection Agency (“EPA”) proposed changes to the RMP Rule . On December 21, 2016, the EPA disclosed its changes via a Pre-Publication Copy.

In the proposed rule, the EPA essentially agreed that the scope and trigger for post incident investigation was not universally understood or applied.

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