(69b) The Facility Siting Cycle (Revalidation)

Facility siting is an assessment of occupied buildings given potential explosion, fire, and toxic hazards. As stated in 29 CFR Part 1910, it is requirement for Process Safety Management covered processes. Sites and processes are always changing and maintaining a facility siting study in-line with these changes, as a part of the Process Hazard Analysis, is required by 29 CFR Part 1910 section 6.e to be performed at least every five years. While maintaining a current facility siting study can be a challenge, revalidation has many benefits aside from ensuring a safer working environment. Revalidation studies are initially seen as opportunities for sites to address large site changes (e.g. new process units, changing process conditions, changes in occupied buildings). However, other benefits from revalidation include: 1) Inclusion of various preliminary or detailed studies into a single revised facility siting study, 2) Taking into account any risk or hazard mitigation implementations since the previous study was issued, 3) Benchmarking the progress of the facility siting remediation plan, 4) Evaluate and revise existing hazard criteria, 5) Take advantage of modeling, software, and methodology improvements, and 6) Assessing the effectiveness of the Management Of Change (MOC) system to identify changes to the site that influence facility siting. For example, are there any new occupied buildings or building improvements that were not captured by the current MOC process? This paper discusses the different ways to approach revalidations studies, what sites should expect during revalidation, and the additional opportunities/insights that can be recognized beyond the study itself.