PHA Methodology Selection — OSHA Letters of Interpretation

A company asked OSHA to approve the Zurich Hazard Analysis method. OSHA declined to approve it and explained that the standard (now (e)(2)(vii)) lets employers use "an appropriate equivalent methodology." It is the employer's job to evaluate that method, and the employer is in compliance if the method achieves the rest of the standard's requirements and its objectives.

OSHA said PHA documentation should follow the general format of the methodology used, recognizing that techniques such as HAZOP vary and that vendor software has its own formats. What matters is that the method actually identifies, evaluates, and controls the hazards of the process.

OSHA said the standard does not require formal training for PHA facilitators or team members. But the team must include someone knowledgeable in the PHA methodology being used, and OSHA may review training records and interview team members to judge whether that requirement was met.

A law firm asked OSHA to review its PHA revalidation procedure. OSHA said (e)(6) only specifies that revalidation happen at least every five years by a team meeting (e)(4), and that it does not require an all-new PHA. But the revalidation must at least: evaluate the existing PHA against every (e)(3) item; confirm changes since the last PHA went through MOC and are reflected; confirm all PSI is complete and current, not just P&IDs; verify procedures are adequate and followed; confirm prior recommendations were documented and implemented; and review every incident investigation report under (m) and incorporate it. The revalidation must be documented.