(126a) Evergreening Your PHA

The PHA, LOPA, and other process safety information have all been documented. The hazards and safeguards/independent protection layers have been identified. Some time later a device is altered. Is this device a potential safeguard? How does this affect the process and how is this documented? Is the hazard, other safeguards, or any other information affected?

Today as changes are made to operating facilities, they are documented, approved and filed away. The changes are then reviewed during the five year revalidation PHA. Critical information could be buried or inaccessible. In the future, an evergreen database of information can be used to ensure that safeguards/independent protection layers are not eliminated or altered without proper investigation, engineering, and documentation. In addition, maintenance activities need to be able to be tracked and verified if the safeguards/independent protection layers are to be relied upon. PHA safeguards and/or LOPA IPLs should be available in one easily accessible location so they can be retrieved, reviewed, and updated as changes are made to the facility. This paper will address procedures, policies and/or technologies to significantly improve access, availability, and accuracy of this information.