(14a) Recipe for a Complete Process Hazard Analysis – Especially Addressing the Key Demands from US CSB

Process Hazard Analysis (PHA) is not a new topic. Surprising, more that 80% of PHAs performed today do not comply with the current interpretations by US OSHA, much less the industry best practices. Most PHAs address less than 10% of the hazards during startup, shutdown, and online maintenance¹ and less than about 30% address damage mechanisms such as corrosion, erosion, external impacts, external stresses, vibration, etc. How to address these hazards has been part of the CCPS Guidelines for Hazard Evaluation Procedures since 1991 and the US CSB and US OSHA have noted how these weaknesses have led to many accidents. The citations and comments from US regulators and the CSB are detailed to provide some of the business case for performing more thorough PHAs on these key issues. This paper and presentation also illustrates step-by-step how to address all hazards of the process during ALL modes of operation, during a PHA. The presentation and paper will use examples of process hazards missed and found to illustrate the importance of this step-by-step approach. The results are based on thousands of unit-sized PHAs performed or managed by PII staff.