Since August 2012, significant changes have been proposed by a number of agencies to Safety Management Systems Programs, e.g., Process Safety Management (PSM), Risk Management Programs (RMP), and related programs. Many of these are framed within OSHA's and EPA's PSM/RMP Modernization/Expansion Programs, and key technical and regulatory changes are being proposed by Federal OSHA, U.S. EPA, Chemical Safety Board (CSB), and other agencies. A number of these modernization efforts have centered on Process Hazard Analysis (PHA). The main objective of this paper is to provide some tangable suggestions for effectively addressing these proposed changes, with the intent of providing straightforward tips for owner/operator companies to address contemporary best practices and to minimize required upgrades to their PHAs (and other PSM/RMP Program elements), once these new proposals become a regulatory requirement. Key paper topics include:
- Overview of Various Safety Management System Program Modernization Initiatives
- Key Proposed Changes to the EPA’s & OSHA's RMP/PSM Modernization/Expansion Program
- Evolution of PHA Requirements/Methodologies
- PHA Tools Used in Contemporary Best Practices
- PHA Tools Used to Address Specialized Needs
- Tips for Managing Your Current Efforts to Address Evolving PHA Guidelines
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