(141b) Refinery PHAs – Revalidation or Re-Dos? Do They Ensure Safe Operations?

OSHA 1910.119 has been in existence for over 20 years now. Its elements have been clearly rolled out and adopted by the refineries in the USA. On the other hand, the most recent refinery in the country was built over 45 years ago. There have been various initiatives from regulators and operating companies by way of compliance audits, emphasis programs and due diligence, to ensure that the process safety management aspects are followed. While following the path of compliance and conformance to the 14 elements including the every five year occurring Process Hazard Analysis (PHA).

The success of a PHA relies on various factors - choice of methodology, scope inclusive of changes from the last few years, addressing new and earlier unidentified scenarios, tracking of previous actions and incorporation of findings from incidents and lessons learned. While this should be the scope of the PHA, it is often misrepresented with a check the boxes type of approach. The key is ensuring compliance as well as satisfying the requirements of a revalidation or re-do - a choice made by operating company.

It is commonly observed that while sites have completed this five year compliance requirement, some of effectiveness of the PHA is lost due to non-adherence to scope. This paper will provide some illustrations and recommendations to avoid such situations. At the same time, the authors will share their experiences on HAZOPs, What-If and LOPAs in the revalidation/re-do scenarios that have proved to be effective.

Irrespective of the satisfying the five year window and choice between the revalidation/re-do; the only value and effectiveness of the PHA is realized upon continuing to adhere to the claims made in the PHA and addressing the necessary actions to minimize risk.