There is a method to OSHA’s madness in PSM (as well as EPA’s with regards to RMP) when it comes to conducting a Process Hazard Analysis (PHA). Unfortunately too many facilities have been duped into believing that the effort they put forward into what they called a PHA was quite frankly a waste of time. Maybe not a total waste of time, but way too many of these PHA’s fall well short of even resembling some recognizable methodology. For example, a trade group has published a “What-If Checklist” for the type of process their member companies operate. This checklist was supposedly taken from a HAZOP study that was conducted by a team of experts and the scenarios converted over to “what-if” questions for the ease of use by their members. But these “What-Ifs” are NOT “what-if” scenarios! If your “What-if” questions are asking if pressure vessels have relief valves, this is a sign that you may not be ready for a PHA.