One of the most important aspects of a sound PSM program is having a high-quality process hazard analysis (PHA) completed for your covered processes. Many companies turn to third parties for assistance in leading and facilitating their PHAs due to the specialized nature of facilitating PHAs. However, companies may not consider the most important factors when selecting a third-party PHA facilitator.
Companies often focus on factors which may not be the most important in making a decision. These include:
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Overall cost of using a third-party facilitator. Naturally, cost is always of concern when budgets are tight.
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Experience of the facilitator with the company’s specific type of processes. Often, this is one of the biggest considerations.
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How quickly a study can be completed. A company may need study team members to return to their regular duties as quickly as possible.
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Proximity of the facilitator to the facility. It can help to keep travel expenses down.
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How quickly a PHA report can be issued. Frequently, this is a top concern.
Additional factors to consider include:
- The competency of the PHA facilitator. This is of the utmost importance. PHA facilitators must be certified to ensure their competency. PHA studies require special skills on the part of the facilitator.
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The independence of the PHA facilitator. The role of a PHA team leader is to draw information about the process from the PHA team members, not dictate it to the team. Too much knowledge of a process can actually put blinders on a PHA facilitator. A facilitator with little to no knowledge of the process often views things through a different lens than someone with intimate process knowledge. It is better to have a facilitator with a wide range of process experience, spanning multiple industries and many different process types.
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Price is an important factor but should not be the driving factor. Some companies choose the cheapest option, due to a myriad of reasons. Often the cheapest option involves cutting corners, moving through the study too quickly, or using a PHA facilitator who is not competent. “You get what you pay for” is true in almost every facet of life and certainly applies to PHA facilitation. Some companies have policies in place that prevent them from selecting the cheapest option for a service or product when the quality may not be sufficient. That is the sensible route to take in selecting third-party PHA facilitators since poorly facilitated PHAs can have devastating results for process facilities.
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Companies should focus on the level of detail and overall quality of a PHA report, rather than how quickly they can receive it after the study. It is important to get started on PHA action items quickly after a study, but the action items should be based on a quality study if risks are to be reduced appropriately. That’s not to say reports should take months to assemble or that regulatory deadlines should not be met. However, if a report is reviewed by regulators or becomes an exhibit in litigation after an incident, you are going to want a high-quality product that went through proper quality control reviews, and how quickly you received it will not matter.
Does your company use third-party PHA facilitators? Are you considering all of the important factors when selecting a facilitator?