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PT Notes

The Importance of Approvals in PHA Studies

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PHA studies proceed through multiple stages from preparation, through performance, to the resolution and management of study recommendations. Approvals by stakeholders play a vital role in ensuring studies are performed correctly and provide evidence to regulators and other interested parties that studies have been managed properly. Each approval should be documented as part of the PHA study record.

Approvals begin with a Responsible Manager who commissions the study, designates a study facilitator, and provides authorization to proceed with the study. For example, this person may be a plant manager, operations manager, or process safety manager.

The study facilitator embarks on defining the study charter, including the study purpose, scope, and objectives, usually in consultation with the Responsible Manager. Important aspects of the charter include the boundaries of the process and the types of hazards and consequences to be addressed. The charter provides a road map for the study. An inaccurate or incomplete charter results in an inaccurate or incomplete PHA study. Thus, it is essential that the charter should be approved by the Responsible Manager and other facility personnel, as appropriate, for example, the process safety manager.

A key part of study preparation is the collection of process safety information (PSI) such as process drawings and procedures. The validity of a PHA study is dependent on the accuracy and completeness of the PSI. Consequently, it is important that approvals are sought from the individuals responsible for each part of PSI to attest to its accuracy and completeness for the study. Responsible individuals may include operations and maintenance personnel and design, process, control, and safety engineers. Despite such approvals, inaccuracies may be discovered during studies and require recommendations for PSI updates.

The correct selection of PHA team members is another vital task in study preparation as it can make or break a study. Team members should meet established selection criteria to ensure they are qualified and can work together as an effective team. Given the importance of the team, the Responsible Manager or other designated person should approve the selected team members.

Often, checklists are used in PHA studies. For example, protocols for study preparation, or lists of items to be addressed during studies, such as previous incidents and process changes, may be utilized. Each checklist may require approval to ensure it is up-to-date, for example, by the process safety manager or other facility personnel. The use of outdated checklists can invalidate studies and require costly re-work.

QC reviews of PHA studies help to assure their quality. Approval of QC reviews ensures they are actually conducted and provides an opportunity to confirm that the QC review itself was performed properly and that any PHA deficiencies identified were addressed. Typically, this approval is provided both by the Responsible Manager and other technical personnel.

Once studies have been completed, recommendations for corrective actions that were made during a study must be addressed. Decisions may be to reject a recommendation, proceed with a recommendation, or consider an alternative recommendation. Approvals support the justifications for decisions and ensure that the necessity, costs, and technical feasibility of recommendations are addressed. Each decision typically is approved by interested parties, such as the plant manager, process safety manager, operations manager, or maintenance manager.

Approvals are easy to overlook but their value should not be dismissed. The use of formal approvals is a hallmark of a well-managed PHA program.

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