PHA & HAZOP Facilitation | Process Hazard Analysis Services

What the Rule Requires

The PHA Requirements, in Plain Terms

OSHA's PSM standard, 29 CFR 1910.119(e), and EPA's RMP rule for Program 3 processes, 40 CFR 68.67, share the same core PHA requirements.

An approved method

What-If, Checklist, What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, or an appropriate equivalent, matched to the complexity of the process. [(e)(2)]

Seven things it must address

Process hazards; previous incidents with catastrophic potential; engineering and administrative controls, including detection; consequences of control failure; facility siting; human factors; and a qualitative evaluation of effects on employees. [(e)(3)]

The right team

Expertise in engineering and process operations, at least one employee with experience specific to the process, and one member knowledgeable in the PHA method being used. [(e)(4)]

Recommendations that close

A system to address findings promptly, document resolution, set a written schedule, and communicate actions to affected employees. [(e)(5)]

Revalidate every 5 years

Updated and revalidated at least every five years by a qualified team. PHAs and the resolution of recommendations are kept for the life of the process. [(e)(6)–(7)]

Current PSI first

Process safety information must be compiled before the PHA is conducted. A PHA built on out-of-date P&IDs or missing relief design data is weak from the start. [(d)]

RMP Program 3 adds more (2024 rule). 40 CFR 68.67 now also requires the PHA to address standby or backup power for release monitoring equipment, siting that includes nearby stationary sources and proximity to the public, natural hazards, and gaps between the codes the process was built to and current versions. Safer technology and alternatives analysis (STAA) applies to NAICS 324 and 325 processes. Under §68.10(g), the backup power and STAA provisions have a May 10, 2027 compliance date. EPA has proposed changes (91 FR 8970, Feb 2026) that are not final. In California, refineries also need a Safeguard Protection Analysis under §5189.1; see our California PSM page.

How We Run a PHA

From Kickoff to Closed Recommendations

Step	What happens
1. PSI readiness check	Before sessions start, we confirm the P&IDs, relief design basis, safe operating limits, and chemical hazard data are current, so the team analyzes the plant as it actually is.
2. Method and nodes	We match the method to the process: HAZOP for complex continuous units, What-If/Checklist for simpler systems. Nodes are defined with a clear design intent.
3. Team roster	We confirm the team meets (e)(4): operations, engineering, an operator who knows the unit, and a facilitator who knows the method. We cover all operating modes, including startup, shutdown, and maintenance.
4. Facilitated sessions	Deviations, causes, consequences, and safeguards, with each safeguard challenged: does it exist, does it work, and is it independent of the cause?
5. Report and worksheet	A complete record addressing all seven (e)(3) topics, including facility siting and human factors, which are often thin.
6. Recommendation follow-through	Each recommendation gets an owner, a date, and documented resolution. That's where the safety value is, and where inspectors look.

See a full node worked through in our HAZOP worked example, built on a real CSB-investigated vessel failure.

When You Need One

Common Reasons Facilities Call Us

5-year revalidation due

A revalidation is a chance to fix what the last study missed, not just re-sign it. We review the previous PHA, changes since then (MOCs), and incidents, then update the study.

New unit or capital project

PHAs at design stages, then a PSSR that confirms recommendations were resolved before startup. For new facilities, the PHA must be done and recommendations resolved before start-up [1910.119(i)].

After an incident or audit finding

When an incident or compliance audit shows the PHA missed a scenario, we help rework the affected nodes and close the gap.

Planning a PHA or Revalidation?

Tell us about your process and schedule. We'll help you scope the study, the team, and the timeline.

Talk to Us PSM Compliance Audits HAZOP Worked Example

Sources

OSHA, 29 CFR 1910.119(d), (e), (i): eCFR
EPA, 40 CFR 68.67 and 68.10 (compliance dates): eCFR · EPA proposed rule, 91 FR 8970 (Feb 24, 2026): Federal Register
Not legal advice. Confirm requirements against the current regulations.

PHA & HAZOP FacilitationThat Holds Up.