Updating the Process Hazard Analysis

D0E-HDBK-1100-2004

7.0 UPDATING THE PROCESS HAZARD ANALYSIS

Each PrHA must be updated and revalidated at least every 5 years to make sure it accurately

reflects current processes and operating experiences.

7.1

Update Team

The PrHA update is performed by a team with expertise in engineering and process operations.

The team must include at least one member who has experience and knowledge specific to the

process, and one member who is knowledgeable in the PrHA method being used. The team

need not include the original PrHA team members, although it may be helpful, for consistency,

to include at least one original member. New team members, however, may bring different

perspectives to the update.

7.2

Approach

Members of the update team should review a copy of the initial PrHA and check completion of

action items. The team should thoroughly review current PSI and descriptions of all process

modifications made since the last PrHA report. A thorough review of the PSI is necessary to

make sure that the PrHA incorporates any new hazardous materials, process technologies,

equipment, and/or operating procedures. Finally, the team should review all findings and

resolutions from the last PrHA to assure that they have been adequately addressed.

If the process has changed extensively, it should undergo a new analysis using a PrHA method

appropriate to its new configuration. If the process has not changed much, the PrHA is updated

considering the changes that were made. Any hazards that were overlooked in the previous

analysis or that resulted from process modifications are added to the PrHA. In addition, "lessons

learned" from other PrHAs should be incorporated where applicable. In some cases, scenarios

may be omitted as a result of risk reduction measures. Updating a PrHA typically takes a third

to a half of the time of the original analysis.

7.3

Documentation

The update team must develop a new PrHA report to document the scope and approach of its

analysis as well as any new hazards, scenarios, and action items. Justification must be provided

for removing any scenarios from the last PrHA. The report should receive close scrutiny, both

for compliance with the PSM Rule and for explanations of new action items. Guidance for

reporting the PrHA results is given in Section 5.1. The updated report is submitted to

management for review and approval, following the same procedure as an initial PrHA.

The PSM Rule requires that PrHAs for all covered processes, along with documentation of

resolutions of recommendations, be retained for the life of the process.