Lack of Proper PHA's = Loss of 12 Lives

In the early hours of a day in May 2020, the coastal city of Visakhapatnam in India was enveloped in chaos. An unfamiliar smell hung in the air, and within hours, a styrene monomer gas leak had covered a radius of about 3 KM (~1.86 miles). This major accident resulted in the loss of 12 lives and reported 1,000 injuries. The post-mortem report revealed that the formation of the deadly vapor was a result of a polymerization reaction, caused by personnel negligence and lack of a proper monitoring system. This incident serves as a stark reminder of the importance of safety in the workplace and the critical role of Process Hazard Analysis (PHA).

Understanding the OSHA PSM PHA Requirements

The Occupational Safety and Health Administration (OSHA) has set a standard known as 29 CFR 1910.119(e), which refers to the Process Hazard Analysis (PHA) section of the Process Safety Management of Highly Hazardous Chemicals. This standard aims to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire, or explosion hazards.

The Key Points of PHA

The PHA is conducted by a team with expertise in engineering and process operations. The team is required to generate specific findings and recommendations for each process covered by the standard. Key points of 29 CFR 1910.119(e) include:

• The employer must establish a system to promptly address the team’s findings and recommendations. The resolution of the recommendations must be documented.
• The actions must be communicated to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.
• A written schedule of when these actions are to be completed must be developed. Actions must be completed as soon as possible.
• At least every five years after the completion of the initial process hazard analysis, the PHA must be updated and revalidated to assure that the PHA is consistent with the current process.

Note: see the regulations for a full list of PHA requirements.

Ensuring Ongoing Compliance

Ensuring ongoing compliance with the PHA requirements is crucial for the safety of employees and the community. This can be achieved through regular audits, training, thorough documentation, open communication, and timely updates and revalidations of the PHA. This is an important reminder of the importance of not getting complacent!

The Consequences of Non-Compliance

Non-compliance can lead to severe penalties, fines, and legal repercussions. But more importantly, it can lead to incidents like the one in Visakhapatnam. The goal of these standards is not just to enforce regulations, but to ensure the safety and health of employees and the community.

Wrapping Up

Looking back at the incident in Visakhapatnam, we are reminded of the importance of safety in the workplace. The PHA is not just a regulatory requirement; it’s a tool that helps us prevent incidents and protect our employees and the community.

So, I leave you with this question: Is your company doing everything it can to ensure the safety of its employees and the community? Remember, safety is not just a requirement; it’s a responsibility.

Disclaimer: this is not legal advice and should not be construed as such.