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.
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.
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.
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.
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