Process Hazard Analysis (PHA) OSHA PSM 1910.119(e)
An initial PHA and a five year revalidation using HAZOP, What If, Checklist, FMEA or another appropriate method
Process Hazard Analysis (PHA)
OSHA PSM 1910.119(e)
OSHA PSM 1910.119(e) requires an initial PHA on each covered process and a revalidation at least every five years. The element names the acceptable methodologies, namely What If, Checklist, What If and Checklist, HAZOP, FMEA, Fault Tree Analysis or another appropriate equivalent, yet it does not prescribe one, because the right choice depends on the complexity of the process. The element also defines a mandatory scope that covers the hazards, the previous incidents, the engineering and administrative controls, the consequences of failure, the facility siting, the human factors and the qualitative evaluation of safety and health effects. The five year revalidation is not negotiable, and CSB findings have repeatedly named expired PHAs as contributing causes. Modern execution by our team integrates IEC 61882 HAZOP, CCPS LOPA, IEC 61511 SIL allocation and CCPS Bow Tie into one workflow.
How the study is executed
A structured, facilitated process that runs from scope definition through close out and produces defensible, actionable outputs.
Match method to process complexity per (e)(2), HAZOP for continuous, FMEA for batch / equipment focused, FTA for failure mode focused.
Multi discipline team per (e)(4), operator, engineer, process safety, with PHA expertise, integrate contractor representation where applicable.
Per (e)(3), hazards, previous incidents, controls, consequence, siting, human factors, qualitative safety/health evaluation.
Capture recommendations with risk ranking, owner, target close out per (e)(5), integrate with MOC and corrective action.
Per (e)(7), retain PHA records for life of process plus retention, integrate with EDMS and PSI.
5 year revalidation per (e)(6) with MOC trigger partial revalidation, track expiry to prevent gap.
What the study covers in full
Outcomes of Process Hazard Analysis (PHA) OSHA PSM 1910.119(e)
- We surface the catastrophic release scenarios
- We align engineered safeguards to each scenario
- We clarify operator action expectations
- We establish the Bow Tie barrier register
- We give you a confident response on OSHA 1910.119(e)
- We follow the CCPS PHA Guidelines third edition
- We apply the IEC 61882 HAZOP standard
- We satisfy MSIHC Schedule 1 in India
- We capture the operability findings
- We support better procedure design
- We strengthen the MOC baseline so it needs less rework
- We give you a defensible five year revalidation
- We catch issues at FEED where they cost 10 to 100 times less to fix than after startup
- We strengthen your insurance position
- We help you avoid a major accident
- We sharpen capex efficiency
Codes & standards we work to
Triggers that signal the need
Where Process Hazard Analysis (PHA) OSHA PSM 1910.119(e) applies
Wellheads, separators, gas compression, FPSO topsides, produced water systems.
Distillation columns, reactors, heat exchangers, storage spheres, LPG handling.
Cryogenic exchangers, liquefaction trains, BOG compressors, storage and sendout.
Reactive systems, batch reactors, solvent handling, runaway reaction scenarios.
Boilers, HRSGs, steam headers, hydrogen systems, ammonia SCR units.
Sterile vessels, CIP/SIP, pressure fermenters, solvent recovery, spray dryers.
Tangible deliverables
- A PHA methodology selection rationale
- A PHA workbook with node by node scenarios
- An action register with risk ranking
- A documentation pack per the (e)(7) retention requirement
- A five year revalidation schedule
- MOC integration for a partial revalidation
Ready to start your project?
Speak with our team to scope an engagement tailored to your facility, regulatory context, and lifecycle stage.