(120c) "We Must be Safe, Right? We Had a PHA": Effectively Crafting and Implementing PHA Recommendations

Recommendations are the heart and soul of a Process Hazards Analysis (PHA). PHAs are only as effective as the action taken to implement the recommendations made during the study. They are the key action items made during the PHA session and usually are made in response to an identified risk that needs to be mitigated or investigated. Therefore, if they are not followed through on, the value of the PHA study is compromised, not to mention the safety of the facility.

Valuable information is contained in the PHA worksheets, but because they are long and difficult to read it is often only the action items list that people will see once the session has finished. Therefore, each action item needs to clearly describe the uncovered risk and how to approach mitigating it.

Time and resources are limited, however, so not all recommendations can be implemented. Sometimes further investigation can show that the recommendation is not required, the risk can be tolerated, or an alternative approach would be better. It is vital that recommendations are carefully worded so that they can be correctly followed up on after the PHA study, and management can make effective decisions. Recommendations that are poorly constructed or insufficiently backed up by the analysis may be discounted without due process, and those that are overly restrictive may constrain the close-out action to a sub-optimal solution.

This paper will discuss the ways in which PHA recommendations are used and how that is supported during the PHA, common pitfalls when generating and addressing recommendations, and best practices for crafting recommendations during the PHA to ensure the risk to workers, assets and the environment is as low as reasonably practicable.