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)?
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)).
Source: https://www.epa.gov/rmp/hazard-review-synonymous-process-hazard-analysis-pha