PT Notes
PHA Practices to Avoid: Pre-Entry of Data
PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.
This PT Note is the first in a series to help you ensure your PHA studies follow best practices. Poorly conducted studies expose companies to regulatory and legal liabilities that can cost millions of dollars.
Some practitioners make entries in process hazard analysis (PHA) worksheets before the PHA team meets in order to speed up studies and reduce the time needed for the team sessions. This practice violates the intent of regulatory requirements for process safety and is poor practice as it detracts from the quality of studies.
Some initial preparatory work can be performed by an individual, such as preparing a node list for a hazard and operability (HAZOP) study. However, defining hazard scenarios and developing recommendations to address them must be done by a PHA team to comply with process safety regulations. PHA approaches in which team leaders define node intentions, select parameters and/or deviations to be considered by the team in advance of the PHA study or pre-enter causes, consequences, or safeguards into the PHA worksheets are not acceptable to regulators.
Furthermore, it is not sensible for even a highly experienced team leader to pre-complete PHA worksheets in advance of a PHA study. Although such individuals may be able to identify many of the scenarios for the process, it is unlikely they will be as complete as a study performed by a team. Their knowledge of the process cannot be as thorough as the combined knowledge of all the team members. Also, team brainstorming is needed to flush out situations that no one has yet imagined.
However, the fatal flaw in the pre-entry of data is that team members are not likely to give serious consideration to searching for additional scenarios when presented with a PHA that has been fully or partially completed. Many team members will be inclined to accept the worksheets at face value, or with token changes, as they believe they were completed by an experienced PHA practitioner. Thus, scenarios may be omitted or not captured properly.
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