(14c) Process Hazard Analysis – Are Studies in Itself Good Enough to Reduce Risk?

Despite the advances in processing technologies, construction techniques, inspection methods, and materials, the number of process safety incidents are still increasing, and often the same types of incidents are being repeated. While regulators are enforcing stringent requirements in regards to safety management systems, process safety incident statistics reflect a failure in effective implementation. Upon closer look at the implementation of safety management systems, it becomes evident that the systems were not built on robust risk recognition. A common response in the industry is that we have completed the hazard analysis and risk assessment studies to questions around how risks are managed. Question that needs to be answered is are the studies in itself solve the challenge at hand. What are key elements that are missing in what we are doing and what needs to be done differently or meticulously?

More detailed evaluation shows there are several common challenges in the industry in regards to PHA:

1. Initial PHA done by project team without involving operations resulting in an incomplete assessment

2. Process Technology or Process Safety Information not handed over by the project team to the operations team or the information is not kept up to date

3. HAZOP considered as the beginning and end of PHA

4. PHA outputs not considered in designing the remaining PSM elements. For example, emergency scenarios are not developed based on hazard analysis and the mechanical integrity or asset integrity program is not in line with the operational risks identified

5. PHA not done periodically or when there are changes in process and/or equipment resulting in increase of potential unmitigated risks

6. Lack of Rigor in implementing PHA recommendations

7. PHA conducted without consideration to both major internal and external incidents, and

8. Not considering PHA in the early stages of project design.

This paper will cover the importance of risk recognition and governance and common gaps observed in Process Hazard Analysis using specific examples from different industry sectors.