OSHA requires that PHAs be updated and revalidated at least every five years. But when does the five-year clock start? From the date the PHA team begins work, from the date the study is completed, or from when management accepts the findings? These letters clarify the triggering event and address related questions including whether a partial revalidation satisfies the requirement, what happens when a process undergoes major modification between cycles, and whether a new process's initial PHA resets the clock. Getting the revalidation schedule wrong by even a few months can produce a multi-element PSM violation.
What OSHA Has Said
⚡ Key Compliance Takeaway
Track revalidation completion dates, not start dates, and schedule your next cycle to finish before the five-year anniversary. A unit-by-unit approach is acceptable but each unit's clock runs independently. Major modifications that trigger MOC and PHA update reset the clock for those sections.