A Process Hazards Analysis is NOT an “engineering review” – Part II

Earlier this week I struck a nerve with many of you; mostly positive comments and agreement and I appreciate all your support.  I received some challenges and I appreciate those as well as they push me to become a better safety professional.  Most of the challenges were of the position “it is not wrong/improper” to ask those type of questions in a PHA and “OSHA/EPA can not cite a facility who ask those questions”.  I agree with BOTH of those positions, however; in use of the said “checklist” I referred to in Part I if that is the only questions your PHA is asking, then OSHA/EPA could find issues with your PHA – not to mention the team members and management not realizing the true value of a PHA.  A PHA should be asking the questions that would lead to the need for a relief system – not if the relief system is in place!  Let me explain…

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