For those who fall under EPA’s RMP rule, you are familiar with the three (3) program levels your process(s) will fall under and each of these program levels has varying degrees of hazard recognition requirements. Many professionals involved in process safety are familiar with the term Process Hazards Analysis (PHA), but an RMP Program 2 process is NOT required to conduct a PHA. A process that meets the definition of a Program 2 process is REQUIRED to conduct what EPA calls a “Hazard Review”, which is a different and less demanding type of hazard review. EPA indicates this in a recent FAQ…
Q. Is a hazard review synonymous with a process hazard analysis (PHA)? The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)?
A. No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention program (40 CFR §68.50). The hazard review must identify the hazards associated with the process and regulated substances, opportunities for equipment malfunctions or human errors, safeguards needed to control the hazards or prevent equipment malfunction or human error, and any steps used or needed to detect or monitor releases. A PHA is a requirement of the Program 3 prevention program (40 CFR §68.67). It involves the rigorous step-by-step examination of processes, process equipment and controls, and procedures to identify each point at which a mishap may occur (e.g., a valve failing, a gauge malfunctioning, human error) and examines the possible consequences of the mishap (58 FR 54196; October 20, 1993). To complete a PHA owners or operators may use a “what if” analysis, a checklist, a hazard and operability study (HAZOP), a failure mode and effects analysis, or a fault tree analysis (40 CFR §68.67(b)).
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