Reporting the Process Hazard Analysis cont'd

D0E-HDBK-1100-2004

context of related accident scenarios. Recommendations from related scenarios should

reflect the incidents.

IDENTIFIED HAZARDS.

The identification of hazards is discussed in Section 3.0. This

section should present the hazards as identified. It may consist of or include the MSDSs for

the chemicals involved (see Section 2.1.1).

ANALYSIS METHODOLOGY.

The PrHA method and the justification for selecting it are

presented here. It is not necessary to describe the method if it is listed in the PSM Rule

(e.g., what-if, checklist, HAZOP study, FMEA, FTA). If any other method is used, it must

be described, and the reason for its selection must be presented.

ANALYSIS TEAM.

A list of the team members, their roles, and brief biographical sketches are

included here. Because the PSM Rule requires a team approach, this section should

demonstrate that the PSM team requirements were met. These requirements include

expertise in engineering and process operations, experience and knowledge specific to the

process being analyzed, and knowledge of the specific hazard analysis method.

SUMMARY OF FINDINGS.

The PSM Rule requires a qualitative evaluation of the

consequences of engineering and/or administrative control failures, to show the range of

possible safety and health effects on workers and offsite populations. This information can

be obtained from the PrHA by selecting those scenarios that cover the range of possible

health effects, and then discussing the existing protection (see Section 3.2). It may be

necessary to conduct a rudimentary, quantitative consequence evaluation in order to provide

the qualitative information required.

In addition to describing protection, the summary should point out any mitigation systems at

the facility which were not included in the PrHA (Mitigation is not normally included in a

PrHA. See Section 3.2). Mitigation systems have the potential to reduce accident impact

levels. They include spray systems to reduce release quantities and early warning systems.

The following is an example of information that should be included in the "Summary of

One scenario from the PrHA results in a release of chlorine from a storage

cylinder through an improperly installed fitting. The quantity of chlorine that

could leak is limited only by the diameter of the tubing, assuming the connection

comes completely loose. Based on a rudimentary evaluation of the release of

this quantity of chlorine, it was found that the chlorine concentration that would

be dangerous to workers (lung tissue damage) extends to about 50 meters from

the fitting, with no concern beyond this distance. Workers are not generally in

the area, except for a walk-around inspection once per shift. The worker

conducting the walk-around would probably smell the leak before any health

effect could occur. Administrative protection includes a leak check of the fittings

that the installer performs before leaving the site. Mitigation includes chaining

off and clearly marking the area to minimize casual entry.