PHA Team Composition and Qualifications — OSHA Letters of Interpretation

OSHA said a PHA completed by one person and then handed to a team for review does not meet the requirement in (e)(4) that the PHA be performed by a team.

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.

Asked whether maintenance employees must serve on PHA teams, OSHA pointed to the employee participation plan under (c): employers must consult with employees and their representatives on conducting and developing PHAs, so maintenance participation may be required depending on the employer's written plan.

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.