OSHA's National Emphasis Program (NEP) on refineries has concluded. The two most cited elements of the Process Safety Management standard (PSM - 1910.119) in the NEP were Mechanical Integrity and Process Hazard Analysis (PHA).[1]
This session will focus on common problems in PHA and how to avoid them. Although OSHA's data and citations are not commonly available, the problems identified in this session have been collected from interviews with OSHA compliance agents, from conversations with refineries that have been audited, and from personal observations. The personal observations are sourced from the past eleven years of auditing refineries, chemical plants, pipelines, and pharmaceutical companies.
In addition to discussing PHA problems that could result in regulatory citations, the session will additionally offer a selection of best practices from a variety of industries.
This 'Back to Basics' session will assume that attendees are familiar with the regulatory requirements of PSM pertaining to PHA.
Glenn Young, C.S.P.
[1] Information from Region VI OSHA Area Director Dorinda Folse - quoted from the September ASSE meeting, Baton Rouge, LA
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