OSHA requires that a PHA team include at least one employee with expertise in engineering and process operations, and one worker who currently works in the process being analyzed. Beyond this minimum, OSHA's letters address questions about team size, the use of external facilitators, the requirement for independent expertise, and what happens when process knowledge has been lost through turnover. A PHA team that lacks meaningful process operating experience, relying instead on engineers who have never operated the unit, is a compliance weakness that OSHA consistently flags.
What OSHA Has Said
Nov 19, 2001
PHA Team Composition and Employee with Process Operations Expertise
OSHA clarifies that the employee with expertise in engineering and process operations requirement can be satisfied by a single individual with both backgrounds, or by two separate team members covering each area.
Read OSHA Letter ↗
Jul 18, 1994
Employee Currently in the Process and the Practical Requirement
OSHA explains that the requirement for a worker currently in the process means an employee actively working in that process unit, not a former operator or supervisor who has transferred away.
Read OSHA Letter ↗
Jul 26, 1995
External PHA Facilitators and Team Independence
OSHA addresses the use of external consultants as PHA facilitators. External facilitators are permissible, but they do not satisfy the requirement for engineering and operations expertise from the employer's own knowledge base.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
A PHA team built entirely of engineers who have never operated the unit is non-compliant. Every PHA team needs an active process operator, not a former one, and genuine process knowledge from the employer's staff, regardless of who facilitates.