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Communication of PHA study

  • 1.  Communication of PHA study

    Posted 08-25-2017 16:34
    I am the PHA coordinator at my site and I have the responsibility of communicating the findings of the PHA to the site.

    Does anyone have best practice that meets the OSHA standard?

    Robert

    Sent from my iPhone


  • 2.  RE: Communication of PHA study

    Posted 08-26-2017 08:22
    One of the biggest issues I ran into early was too many findings, many of which were not valid findings.  This resulted in a large number of the "findings" being declined by management.  This does not shed a positive light on management ( high rejection percentage) or the PHA team (bad findings).  I recommend scrubbing the PHA while the team is still in session by adding personnel at the manager level to the team to review the findings prior to issuing the PHA report.  This helps to resolve several issues, including:
    1. Findings from misunderstandings of the technologies.  Frequently the engineer assigned to the PHA team was young and relatively inexperienced, although they were the engineer assigned to that unit.  A more senior engineer or manager was able to explain additional safeguards already in place or physical limitations that would prevent certain scenarios from occurring.
    2. Findings from pet peeves.  Operations personnel occasionally complained about things like changes to the colors on CBT screens or difficulty in accessing certain indicators.  Unless these are truly process safety issues, they should not be listed as PHA findings.
    3. Occupational safety issues.  Although valid concerns, these are better addressed as issues identified during the PHA, not as PHA findings.
    4. Findings from misapplication of the risk matrix being used.  More senior engineering and operations personnel may have a better sense of how likely a scenario is to occur and/or how significant the outcome would be.
    By reducing the findings to only those that are truly PHA findings, it will be much easier to communicate the findings to the site.  I also recommend having members of the team present at the communications meeting to explain the thinking behind the findings.  One last thing: the sooner the better.

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    Barry Bennett, CCPSC
    Three Rivers TX
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  • 3.  RE: Communication of PHA study

    Posted 08-30-2017 10:21

    ​Bow-Tie diagrams are an excellent way to communicate a summary of the threats, potential consequences and safeguards (barriers) to plant personnel.  They can also be used to highlight who is responsible for maintaining the safeguards.  Watch for the upcoming CCPS book on Bow-Tie analysis, and/or read some excellent recent articles, such as:

    Pitblado, Robin (DNV GL) et al. 2017. "Current State of Bow Tie Risk Assessment Method." In 13th Global Conference on Process Safety, San Antonio, TX: AICHE / CCPS. https://www.aiche.org/conferences/aiche-spring-meeting-and-global-congress-on-process-safety/2017/proceeding/paper/72b-current-state-bow-tie-risk-assessment-method.

    Vaughen, Bruce, and Kenneth Bloch. 2016. "Use the Bow Tie Diagram to Help Reduce Process Safety Risks." Chemical Engineering Progress (December): 30–36. https://drive.google.com/open?id=0B9D_Y3EPgQlsWTVCYnlkWmQ1TUE.



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    Martin Timm PE,CSP
    Corporate Process Safety Manager
    Praxair, Inc.
    Tonawanda, NY
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  • 4.  RE: Communication of PHA study

    Posted 05-27-2020 22:33
    Edited by Michael Saura 05-27-2020 22:34
    Hello Robert,

    As a facilitator for several refineries and chemical manufacturing plants, here are my thoughts:
    • If possible, have weekly reviews with the team to understand major findings/recommendations, OR
    • Have the facilitator provide consistent updates to you and the team so you can have a peek at the recommendations and discuss with the team as needed
    • At the end of the PHA, have a technical review with the facilitator and your subject matter experts (or senior engineers/operations) prior to reporting findings to leadership/management for acceptance of recommendations. This helps ensure a well-screened set of recommendations.
    • During the management meeting, if possible, have all team members in the meeting so they can explain and discuss their findings (this may or may not include the facilitator/chair, depending on your workflow)
    • Once recommendations/findings have been approved, provide/present the recommendations to the plant personnel (operations, maintenance, etc) that may potentially be affected by the unmitigated risk.
    • I also agree with Martin regarding using bowtie. Bowtie provides a simple, visual representation of how to manage risks that would be much more difficult to explain otherwise. This graphical explanation can be EASILY UNDERSTOOD by people at all levels – from operational personnel, senior managers to regulators, and the public. And since Hazard and Operability (HAZOP) is the most commonly used Process Hazard Analysis (PHA) technique in the industry, some people call Bowties the "VISUAL HAZOP."
    I hope this helps and feel free to reach out if you have further questions.

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    Michael Saura
    Process Safety Consultant - Founder
    Saltegra Consulting LLC
    www.linkedin.com/in/michael-s-8604202a
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  • 5.  RE: Communication of PHA study

    Posted 05-29-2020 12:03
    To answer your question, it is useful to remember where that requirement came from.  Per 1910.119(c)(3), "Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard."  So the requirement to "communicate the findings" in 1910(e)(5) is a separate, additional requirement beyond mere access.

    When the reg was first proposed, OSHA's draft language required that processes be shut down until all PHA findings were resolved.  Industry pushed back hard on that draft language for many reasons, and the compromise language issued in the final reg was that "the recommendations [be] resolved in a timely manner."  But this created a dilemma.  OSHA is the advocate for worker safety, yet the reg says it is okay to operate with known process safety deficiencies.  The solution was the requirement for communication of the PHA findings to those who work in the work process and who might be affected.  In addition to notifying workers of the elevated process safety risk, the communication should also tell the workers what is being done to manage the risk in the interim and give the workers a opportunity ask questions and provide comments.  It is exactly analogous to discovering any other safety hazard, like a hole in a walkway.  Workers should be notified of the danger, and the hole should be barricaded until it can be fixed.

    So back to your question.  PSM is a performance based regulation, which gives you the flexibility to implement a system that efficiently meets the requirements.  I have seen companies implement it in a variety of ways - everything from a special employee meeting soon after the PHA was issued to inclusion as a topic in regularly scheduled safety meeting(s).  The main thing is that your system communicate to all the workers potentially exposed to the elevated risk, including those who might be out sick or on vacation.  I recommend that you keep some record that the communication took place in case you are audited on this requirement.  But I caution you that an e-mail blast simply notifying workers that the new or revalidated PHA has been issued and is available for them to read does NOT meet the intent of the requirement.  That is "access," not "communication."

    Lastly, I must generally disagree with the previous recommendations for bow-tie.  The bow-tie technique is a good risk communication tool, but it is not a "best practice" for this particular purpose.  PHA findings are specific deficiencies that must be communicated; bow-ties show how barriers that are in place should reduce the risk of harm.  In addition, development of bow-ties could involve significant additional expense, and many of the detailed PHA findings would be difficult to show in a bow-tie format.


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    Donald Lorenzo PE
    Director, Training Solutions
    ABS Group
    Knoxville TN
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