Considering failure of engineering controls in a PHA

A Process Hazards Analysis (PHA) may very well be the best tool that has come along to the safety profession since the fire extinguisher!  I am kidding of course, well sort of, as the PHA methodologies (and there are many) can be used in so many situations that it is used outside of PSM/RMP as often as it is within the standard requirements of the government regulations.  PHA’s were not developed for OSHA’s PSM standard; they were around long before that standard was even a thought within the ranks of OSHA.  But as with any tool, it can be, and unfortunately often times it is, misused in its application and method.  This is what I mean…

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