I have spent much time with clients doing “Engineering and Code Reviews.” These have been instrumental in avoiding many issues when it comes time for the INITIAL PHA. Depending on the process size and complexity, these can take 0.5 – 3 days, but that time is spent ensuring the primary containment systems and all the layers of protection that come into play for the PREVENTION-PROTECTION-MITIGATION of events at least meet the design codes applicable to the process. But the real advantage is…
Once we do the initial PHA, the proverbial clock begins for addressing the PHA recommendations. But if we perform this Engineering & Code Review before the PHA, we can head off a lot of the “Oh Shit” moments that may arise during the initial PHA. This allows the business time to address any concerns that may arise from the Engineering & Code Review BEFORE the clock starts ticking as if it was discovered in the PHA.
Remember, once the concern has been identified in the PHA, it MUST be addressed BEFORE the PSSR can be signed off on and the process receives the HHC/EHS…
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1910.119(i)(2)(iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; … |
For example, a recent Engineering and code Review for a flammable liquids process identified a design flaw I wrote about a few months ago: Secondary Containment.
This design error, caught BEFORE the secondary containment was poured, saved the business hundreds of thousands and prevented many future compliance and safety issues.