Streamlining PHAs with Pre-Population, Pre-Work, and Creativity

This presentation and paper will focus on how PHAs can be conducted using a minimal amount of resources, while still maintaining high quality results that are sustainable and in accordance with AICHE-CCPS publication guidance (and in accordance with regulations).

In the fall of 2010, I made a career move that landed me at a facility that had 33 employees. This was very different than the 1,000+ employee facilities at which I had spent most of my career. As I quickly learned, a small facility doesn't necessarily equate to small hazard. At this same location, there are over 50 different products manufactured, of which over 50% utilize highly hazardous compounds (HHCs). There are at least 10 different substance specific chemicals where threshold quantities listed within EPA or OSHA's HHC list are exceeded. Needless to say, high quality process hazard analyses are critical to the operation of this facility.

This paper and presentation will outline the tools and techniques that were effectively utilized to conduct and document process hazard analysis for all of the HHCs at this multipurpose batch manufacturing facility. The first challenge delivered when arriving at this location was the decision to “Redo” instead of “Revalidate” each PHA. This management mandate drove the resources at the site to be creative in identifying options that would serve as the best method to achieve such a lofty goal. For any small facility or company, it is a challenge to maintain a robust process safety management system, including a current process hazard analysis; however, to drive a “Redo” of every PHA on an aggressive schedule was even more challenging.

Not only was the challenge successfully executed on a local level, but the exercise also forced the development of tools and techniques that streamlined the PHA process for all facilities within the organization. The presentation will provide key techniques used to complete these PHAs on very high hazard operations while the resource availability was very limited, which is expected for most smaller companies. The exercise was a great reminder that we need to step back and find simple solutions to lofty goals.