QC-PSM-PRO-00-0001

SAFETY

Rev. 1

PROCESS HAZARD ANALYSIS

1-Oct-2012
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TABLE OF CONTENTS

Rev.

1.

INTRODUCTION/PURPOSE ......................................................................... 2

2.

SCOPE ........................................................................................................... 2

3.

DEFINITIONS................................................................................................. 2

4.

REQUIREMENTS .......................................................................................... 4

5.

RESPONSIBILITIES .................................................................................... 15

6.

REFERENCES ............................................................................................. 15

7.

ATTACHMENTS .......................................................................................... 15

8.

APPENDICES .............................................................................................. 15

Issue Date

Prepared
By:

Amendment Description

Reviewed
By:

Approved
By:

Roehl
Bartolome

Carl
Poldrack

Included additional scope requirements

for PHA initiated by MOCs.
1

1-Oct-12

01-Jul-09

Procedure updated to align with global

OE procedures EHS-6205, EHS-6200
and EHS- 6100.
Revised to reflect current work process.
Document classification changed from
policy to procedure, number is now
QC-PSM-PRO-00-0001 Rev. 0.

Next scheduled Periodic Review :October 2015

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Venkata
Chandra

Roehl
Bartolome

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1.

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INTRODUCTION/PURPOSE
The OSHA PSM Standard and the OE system require the conduct of Process Hazards
Analysis (PHA) to manage the process safety risks of operations.
This procedure is intended to establish a consistent process for evaluating process
hazards associated with facility operations.

2.

SCOPE
This procedure is applicable to the Q-Chem manufacturing facilities in Mesaieed and
Ras Laffan.
This procedure covers PHAs that have broad process coverage and are subject to
periodic revalidation. This also covers single purpose PHAs such as those required by
MOC and other work processes.

3.

DEFINITIONS
Cause-by-Cause HAZOP: a Hazard and Operability study in which there is an explicit
correlation between the consequences, safeguards, and actions to each particular
cause of a deviation.
Complex PHA method: for the purpose of this procedure, the HAZOP/LOPA method.
Consideration a method for risk reduction, required by EHS-6100 Risk Ranking
Matrix, made by the PHA Team for management review and evaluation.
Consequence: the undesirable result of an incident, usually measured in terms of
health/safety effects, environmental impacts, loss of property, and business costs.
Deviation-by-Deviation HAZOP: a Hazard and Operability study in which all causes,
consequences, safeguards, and actions correlate to a deviation.
Enabling Event: An event or condition that makes possible another event.
Expected Outcomes reasonable consequences considering only those conditions
explained in the cause description. Other failure conditions [such as event escalation
(a leak continues to get worse), the probability that a toxic material is directed toward
breathing space, the probability of use, or the probability of multiple personnel in the
area] are not considered when determining consequences unless stated in the cause
description and reflected in the cause frequency.
Frequency: number of occurrences of an event per year.
HAZOP-LOPA Analysis a scenario-based hazard evaluation procedure, in which a
team uses a series of guide words to identify possible deviations from the intended
design or operation of a process, then examines the potential consequences of the
deviations and the adequacy of existing safeguards.

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The HAZOP-LOPA includes an analysis of each scenario using predefined values for
the initiating cause frequency, independent protection layer failure probabilities, and
consequence severity, in order to compare an order-of-magnitude scenario risk
estimate to risk criteria.
Hazard: an inherent chemical or physical characteristic that has the potential for
causing harm to people, damage to property or the environment, and/or adverse
impact or interruption to the normal flow of business.
Initiating Event: The event, which initiates the scenario that is leading to the
undesired consequence. It is referred as the initiating cause.
Independent Protection Layer (IPL): A special class of protection layers that satisfy
the following conditions:

Independent from the initiating event and any other protection layers;

Capable of being evaluated or validated for performance;

Must reduce the frequency of the scenario by at least an order of magnitude;

and

Must completely prevent the scenario without the assistance of any other
protection layer.

Mitigated Risk: the risk of an event with consideration given to existing IPLs.
Process Hazard Analysis (PHA): An organized and systematic effort to identify and
analyze the significance of potential hazards associated with the processing or
handling of highly hazardous chemicals by focusing on equipment, instrumentation,
utilities, human actions, and external conditions that might affect the process.
It includes some or all of the following activities: hazard identification, consequence
analysis, hazard evaluation, past incident evaluation, human factors evaluation, facility
siting evaluation, risk assessment, and development of recommendations.
Residual Risk: The risk of an event with consideration given to existing IPLs and
recommended actions.
Safeguard: Any device, system, or action that is likely to interrupt the chain of events
following an initiating event, or that mitigates the consequences of a hazardous event.
A safeguard may not meet the requirements of an IPL.
Severity: a measure of the magnitude of a consequence.
Simple PHA Methodology: for the purpose of this procedure, What-If, Checklist,
What-If/Checklist, and Failure Modes and Effects Analysis (FMEA) methodologies.
Unmitigated Risk: the risk of an event without consideration given to existing
safeguards.

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4.

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REQUIREMENTS
4.1

Identifying PHA Categories

4.1.1 There are two categories of PHAs.
Broad Process: studies which cover large systems or entire process
units.
Single Purpose: studies which cover specific equipment or smaller
sections of the process. Single purpose PHAs are generally required
by MOC, incident investigations, or other work processes.

4.2

Selecting a PHA Method

4.2.1

PHA methods may be classified as simple or complex. Simple methods

shall be one of the following: What-If, Checklist, What-If/Checklist, or
FMEA.

4.2.2

If a complex method is required, the method shall be HAZOP/LOPA.

Specific requirements for the HAZOP/LOPA method are covered in the

Global OE Procedure EHS 6200 Hazard and Operability Study with
Layer of Protection Analysis.

4.2.3

The PHA method chosen shall be a method that is a scenario-based and

single-failure type.

4.2.4

The selection of the PHA methodology shall consider the relative hazard
and complexity of the process to be studied and the hazards of the
materials in the process. If any two characteristics in below table indicate
a complex method, a complex method shall be considered.

4.2.5

If one or less characteristic in below table indicates a complex method, a

simple method may be considered. A PHA may use multiple
methodologies in the same study depending on the processes covered.

Characteristics for PHA Method Selection

Characteristic
Simple Method
Complex Method
Complexity
of
the
process
Simple/Small
Complex/Large
Type of process
Utility
Hydrocarbon/Chemical
Type of operation
Batch
Continuous
Toxic,
Flammable,
Corrosive,
Physical, Explosive,
Reactive,
Nature of the hazard
Asphyxiant
Radioactive
4.2.6

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The PHA Facilitator shall determine the appropriate methodology and

provide the reasoning behind the choice in the PHA documentation. The
rationale for selecting the methodology used in the PHA shall be
addressed in the PHA report.

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4.3

4.3.2

4.3.3

4.5

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Preparation for the PHA

4.3.1

4.4

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Broad-process PHAs shall be initiated and coordinated by the Process

Safety and Compliance group.
Single-purpose PHAs shall be initiated and coordinated by a
representative of the affected group (i.e. MOC facilitator, investigation
coordinator, etc.)
The initiator shall form the PHA team, compile process safety information
and other associated documents, and develop a schedule for the study.

PHA Scope
4.4.1

The process unit owner and the PHA facilitator shall define the scope of
the study.

4.4.2

Physical boundaries of the PHA shall be identified on piping and

instrumentation diagrams (P&IDs) or other drawings by designating a
specific process connection or hand-over point that can be identified in the
field. Marked drawings shall be maintained with the PHA report as part of
the archive documentation. The PHA facilitator shall assure that no gaps
exist between PHAs such that equipment or operations go unanalyzed.

4.4.3

Utilities and environmental control equipment connected to the process

shall be included in the PHA boundaries unless a separate PHA covers
the utilities and environmental control equipment.

4.4.4

At a minimum, the PHA shall consider impacts to workers, the public, the
environment and economics. If a risk evaluation is to be performed, the
PHA shall follow the guidance in EHS-6100 Risk Ranking Matrix.

4.4.5

If the process being studied is partially incomplete (e.g., incomplete

vendor packages), those incomplete sections shall be excluded from the
scope of the PHA and analyzed separately.

4.4.6

For PHAs which are initiated by MOC, the PHA team shall ensure that all
possible scenarios or conditions are identified and included in the scope of
the study. These include:
Normal Operations
Idle / Standby Conditions
Batch Operations
Precommissioning/Commissioning Operations
Decommissioning/Shutdown Operations.

PHA Team
4.5.1

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Core Team. The process hazard analysis shall be performed by a Core

Team. The core team shall consist of at least three (3) people. The
combined experience of the Core Team shall be at least 20 years for
simple PHA methods and at least 30 years for complex PHA methods. At
a minimum, the Core Team shall have the following expertise:

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Methodology Experience. One member shall be trained in the PHA

method being used. This person shall serve as the PHA Facilitator.
Broad process PHAs shall be led by a facilitator certified as
per the requirements of Global OE Procedure EHS-6206
(PHA Facilitator Competency Assessment).
Facilitators for single purpose PHAs need not be certified
to EHS-6206 requirements.

Engineering. At least one person on the core team shall have an

engineering degree and three (3) years of technical experience. The
person with engineering experience shall have experience with the
process being studied.

Process Operations. At least one person on the core team shall

have a minimum five (5) years experience with operating the
process being studied or a similar process.
The employee with process operations experience assigned to the
PHA should have previous start-up, shutdown, emergency, and
normal operating experience with the process.
This role could be filled with an operator or a first-line supervisor.
Where appropriate, it is recommended that an hourly employee be
included in the PHA. It is preferable to have more than one
operations representative.

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Process Experience. One person shall have experience in the

process. The person shall have a thorough understanding of the
process or supply chain operation. It is preferred that this person be
from Research & Technology or from another plant with a similar
process; however, this experience may be fulfilled by any person
fulfilling the above three areas of expertise.

Personnel fulfilling the expertise requirements for the PHA team

must be present for the entire duration of the PHA. If personnel
fulfilling the expertise requirements cannot meet, the PHA meeting
must be postponed.

The Core Team should remain constant throughout the PHA; it is

not desirable to substitute personnel. However, in the rare case
where substitution is necessary, allowance for stand-ins may be
made with approval of the PHA facilitator, so long as the stand-in
meets the minimum requirements of the role.

Supplemental Team Members. Other discipline experts may be

assigned to the PHA full time or part time as appropriate. However,
the PHA Team should not exceed ten (10) members in the PHA
session. Supplemental Team Members shall have experience with
the process under review or similar process equipment.

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Examples of Supplemental Team Members include the following.

4.6

Technical Representatives - i.e., a Mechanical Engineer, Civil

Engineer, Electrical Engineer, and Instrument Engineer. These
personnel may augment the team as appropriate.

A Process Chemist with experience in the process being studied or

similar processes.

Equipment Inspectors.

Maintenance and/or Instrument Technicians.

Safety and/or Environmental Engineering Specialists.

Process Automation Specialists.

External experts from sister facilities or Research & Technology are

encouraged in order to increase the effectiveness of the evaluation
and to promote sharing of process safety information and strategies
within the company.

Scribe. In addition to the Core Team, the PHA team should include
a scribe to record the PHA study. This scribe should be a separate
person from those team members above and should not be included
in the calculation of the team experience.

Process Safety Information (PSI)

4.6.1

Process Safety Information (PSI) shall be available to the PHA team

during the PHA on existing facilities and projects.

4.6.2

PSI relevant to the PHA shall be current and accurate.

4.6.3

PSI required includes the following.

Hazards of the Chemicals Used or Produced by the Process
Material Safety Data Sheets (MSDS)
Corrosively data
Hazardous effects of inadvertent mixing of materials that may occur
Reactivity matrix
Technology of the Process
A block flow diagram or simplified process flow diagram
Process chemistry
Maximum intended inventory (normal maximum inventory)
Safe upper and lower limits for such parameters as temperature,
pressure, flows, levels, or compositions.
Equipment in the Process
Accurate P&IDs

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Plot plan of site

Mass and energy balances
Design codes and standards employed
Safety systems (interlocks, detection, or suppression systems)
Relief system design and design basis
Ventilation system design
Electrical classification
Equipment design (capabilities/ capacities/ design temperature and
pressure/ materials of construction)

Additional Information Requirements

Operating and maintenance procedures
PSM incident and near miss investigation reports from the subject
plant and other plants
MOCs related to the process since the last PHA
4.7

Conducting the Study

4.7.1

Initial Team Meeting

A complete, team-based review of a facilitys process hazards and risks
includes several elements in addition to the use of one or more hazard
evaluation methods. These elements include training in the methodology
being performed (for those team individuals not familiar with the
methodology) and an overview of the process (e.g., a review of the
process chemistry and block flow diagram).

4.7.2

A review of the methodology or methodologies chosen for the PHA shall

be provided to all team members in order to prepare the team members
for active participation in the PHA. A review of the risk analysis used to
rank scenarios must be provided.

4.7.3

Knowledgeable personnel shall provide a process overview to the core

team members. The process overview shall include a review of the
process chemistry and hazardous materials, the flow of materials in the
process (including a block flow diagram), the equipment, process controls,
and safety systems.

4.7.4

Evaluation of Process Hazards

The PHA team shall evaluate process hazards based upon the nature of
the chemicals involved (toxicity, flammability, etc.), the process conditions
(flow, temperature, pressure, composition), the teams experience, and
information about previous incidents both in the facility and at other sites.
Material safety data sheets (MSDSs) and similar information shall be used
in understanding the potential effects specific process materials have on
personnel; however, MSDSs alone do not always identify all of the
pertinent hazards (e.g., properties of significant, potential contaminants).

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4.7.5

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Previous Incidents
The PHA team shall evaluate the results of the incident investigations of
previous PSM incidents. Previous incidents shall include incidents at the
facility being analyzed, at similar CPChem facilities, and at other company
facilities where information is available. The PHA Facilitator shall assure
that all previous incidents identified are cross-referenced to specific
scenarios in the PHA where that incident was analyzed.

4.7.6

Facility Siting
Facility Siting shall be reviewed by the PHA team. The Facility Siting
review shall be in two stages: (1) globally for the unit/site and (2) as part
of the PHA scenario evaluation. The PHA team shall identify hazards
caused by siting issues to equipment, building, and personnel locations
and recommend ways to reduce the hazards. Detailed stand-alone facility
checklists (such as those on the CPChem PSM Best Practices Network
SharePoint site) and building siting studies may augment the global
facility siting review.

4.7.7

Human Factors
Human Factors shall be reviewed by the PHA team. The Human Factors
review shall be in two stages: (1) globally for the unit/site and (2) as part
of the PHA scenario evaluation. The PHA team shall identify hazards
caused by human factor issues to equipment, building, and personnel
locations and recommend ways to reduce the hazards. Detailed standalone facility checklists (such as those on the PSM Best Practices
Network SharePoint site) may augment the global human factors
review. Potential human errors shall be considered as causes of process
upsets. The team shall estimate whether operators would have adequate
time, information, and equipment to respond to deviations (i.e., to
contribute to incident prevention and mitigation).
Routine operating procedures and other non-routine procedures (e.g.,
startup, shutdown, emergency, and maintenance procedures) should be
analyzed to uncover error-likely situations that could result in catastrophic
consequences.

4.7.8

Causes
Causes (what-if questions, scenario initiating events, etc.) represent the
human and equipment failures and natural events that can result in offnormal process conditions. If the PHA methodology chosen is
HAZOP/LOPA, the analysis shall use the cause-by-cause methodology
rather than the deviation-by-deviation method.

4.7.9

Consequences
The PHA team shall document the reasonable worst-case consequences
for an identified accident initiating event. Worst-case consequences are

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those expected outcomes given existing safeguards fail. Worst-case

consequences reflect only those conditions explained in the cause
description. Other failure conditions [such as event escalation (a leak
continues to get worse), the probability of use or the probability of multiple
personnel in the area] shall not be considered when determining
consequences unless stated in the cause description and reflected in the
cause frequency.
At a minimum, consequences shall include an evaluation of the expected
impact to workers, the public, the environment, and economics. The
consequences shall include a range of impacts and the corresponding
severity. The PHA should also identify any significant security plan design
basis changes or obvious vulnerabilities.
4.7.10 Risk Ranking
The risk associated with the scenario is based on the frequency of the
initiating event (cause) and the severity of the consequence. This can be
derived through the Risk Ranking Matrix.
Where Mitigated Risk level is 5, the PHA team shall do the following;

Immediate site management notification and action required.

Temporary risk reduction measures (Interim Compensating
Measures) that will reduce the risk rank to 4 or less must be put in
place immediately.
Additional temporary risk reduction measures that will reduce the
risk rank to below 4 must be put in place as soon as practicable.
Permanent measures to reduce the risk rank to 2 or less must be
implemented within a specified time approved by site management
and the next higher level of management.

Where Mitigated Risk level is 4, the PHA team shall do the following;

Site management notification and action required.

Temporary risk reduction measures (Interim Compensating
Measures) that will reduce the risk rank to below 4 must be put in
place as soon as practicable.
Permanent measures to reduce the risk rank to 2 or less must be
implemented within a specified time approved by site management
and the next higher level of management.

4.7.11 Engineering and Administrative Controls

The PHA team shall identify existing engineering and administrative
controls, or safeguards, required to bring the risk associated with the
scenario to a no-action level.
These controls may include detection devices that provide early warning
of releases, inventory minimization policies, fire protection systems,

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criteria for equipment spacing, pressure relief devices, and process

instrumentation and interlocks.
Engineering and administrative controls shall be treated as a system that
includes sensing, logic, and final elements. For example, a high pressure
alarm shall be considered as including pressure sensor, pressure
transmitter, distributed control system (DCS), operator (when operator
action is required), final element (e.g., control valve), and miscellaneous
equipment (wiring, etc.) required to successfully respond to a high
pressure deviation and bring the process to a safe condition.
By definition, given the cause, failure of engineering and administrative
controls will result in the consequences identified previously in the
scenario.
4.7.12 Considerations
Where
the
scenario
(cause/consequence/existing
safeguards
combination) fails to meet risk criteria as specified in the EHS-6100 Risk
Ranking Matrix, the PHA team shall identify the scenario for management
attention and, where possible, suggest actions for management to
consider that will reduce the risk to a no-action level.
These considerations must either eliminate or reduce the likelihood of
potential incidents or lessen the consequences associated with the
scenario.
In developing considerations, the PHA team should follow a hierarchy of
strategies or approaches:
1. Eliminate or reduce the underlying hazard (inherently safer options)
Eliminate (remove the hazard altogether)
Substitute (replace a material with a less hazardous material)
Abate (reduce the quantity of material stored, used, or
generated)
Attenuate (modify the process to operate at a lower energy
state)
Dilute (mix a hazardous material with a less hazardous one)
2. Eliminate or reduce the likely cause of the scenario (prevention)
3. Reduce the severity of consequences (mitigation)
4. Increase
the
number
(control/protection)

or

effectiveness

of

safeguards

NOTE:
If the PHA Team has suggestions that are not required for risk reduction
to meet corporate risk criteria, the Team shall maintain a list separate
from the PHA. These suggestions shall be considered separately by
appropriate members of the plant leadership team.

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4.7.13 PHA Follow-up

A record of the PHA shall be recorded in PHAPro software using the
most current template available for the type of PHA performed. The final
PHA file (recorded PHAPro template) shall be loaded onto the common
corporate storage location within 45 days of the final PHA team meeting.
For broad process PHAs, a report documenting the study shall be
prepared for local management review within 90 days of the final PHA
team meeting. The PHA report shall include the following information.

The PHA scope and boundaries.

The rationale for selecting the methodology used in the PHA.

The dates of the PHA.

The name of the process reviewed.

The name of the location.

A biographical sketch of the participants, including their title,

location, PHA team role, and qualifications for filling that role.

A list documenting considerations for management and the

bases used by the PHA team to suggest process improvement.

A list of mechanical integrity covered equipment (MICE) utilized

as independent protection layers (IPLs).

A list of procedures, routine activities, and other safeguards

utilized as independent protection layers (IPLs).

A list of the PSI available during the PHA, including drawings

and revisions reviewed.

The worksheets and checklists produced during the PHA.

P&IDs marked to reflect PHA study nodes.

As noted in the previous section, a list of suggestions not required for risk
reduction (non-risk supported considerations) shall also be prepared.
However, this does not need to be included in the PHA report.
For single purpose PHAs, a copy of the worksheets, considerations, and
other relevant forms shall be generated off the PHA Pro software and
included in the documentation package of the corresponding MOC,
incident investigation, or other process requiring the study. A formal report
is not necessary unless specifically required.

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4.7.14 Management Review

As soon as possible following the final PHA team meeting, the PHA
facilitator shall review the considerations from the PHA with the plant
leadership team so that they can assess the need for any immediate
actions.
The leadership team, and affected members of their respective work
groups, shall review the considerations and prepare action plans within 60
days of the PHA report issue date. This review shall determine
appropriate responses before turning the considerations into action items
and beginning the action item tracking process.
Appropriate responses shall include one of the following;
Accept the consideration as is.
Reject the consideration because the analysis upon which the
consideration is based contains material factual errors (e.g.,
additional safeguards were not considered, calculations were
incorrect, the facility or operation was not accurately represented
in the PHA, etc.).
Reject the consideration because the consideration is not
necessary to protect the health and safety of the employees or
contractors, or to protect the public or the environment from offsite
effects.
Reject the consideration because an alternative measure would
provide a sufficient level of protection.

Reject the consideration because the consideration is infeasible.

The results of the management review shall be documented and reviewed

by the PHA team as available.
Non-risk supported considerations shall be evaluated and reviewed by the
Production Manager and the Superintendent of the affected process unit.
4.7.15 Action Items
Following management review, accepted considerations, or alternatives
shall become action items.
Management shall assign primary responsibility for action items and
establish due dates.
The Action Item Prioritization Matrix in the Compliance Assurance
Program (QC-OEM-PRO-00-0001) may be used to estimate due dates.

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All PHA action items shall be tracked until closure and reviewed monthly
by management. The status of these action items shall be reported
through the process safety metrics.
Action items from non-risk supported considerations should also be
included in the review. However, these items shall not be included in the
process safety metrics.
Management shall communicate the actions to operating, maintenance
and other employees whose work assignments are in the process and
who may be affected by the recommendations or actions.
4.7.16 Document Retention
PHA
documentation,
including
documented
resolution
recommendations, shall be retained for the life of the process.

of

4.7.17 PHA Revalidation

At least every five (5) years, PHAs shall be revalidated to produce an
updated PHA that adequately identifies, evaluates, and proposes controls
for hazards of a process. There are three options for revalidation.
Update and Revalidate
This is the expedient, incremental approach where very little has
changed in the process between the previous and the current PHA. In
this option, the previous PHA is updated to reflect changes, incidents,
and any new learning. For a process that has experienced no changes
or incidents, it may only be necessary to affirm the continued validity of
the previous PHA.
Retrofit, Update and Revalidate
This option reflects one or more reparable defects in the previous PHA.
The sections containing the defects are revised and the PHA can be
updated using the process above.

Redo
A redo is a complete restart of the previous PHA, working from a blank
analysis. There are five basic reasons that could drive a total re-do of a
PHA:
Poor PHA quality.
Multiple serious incident history with root causes that were not
previously addressed in the PHA.
Multiple significant changes since last PHA.

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Length of time (> 5 years) since last total redo. (The revalidation
option must be a redo if the previous PHA was not a redo. A
revalidation shall not be revalidated.)
Opportunity to develop/maintain in-house PHA facilitation
expertise.
For the redo option, PHA quality shall be determined as less than
desired if any of the following are true.

The PHA method used in the previous PHA method was

inappropriate for the complexity of the process studied.

A liberal sampling of the hazard scenarios recorded indicate that:

1. Significant potential safety hazards were not identified.
2. Consequences were documented with inconsistency,
promoting misunderstanding.

Marked-up drawings that were used in the previous PHA did not
accurately represent the field installation.

Attachment A-PHA Revalidation Evaluation further

determining revalidation alternative for previous PHAs.

5.

assists

in

RESPONSIBILITIES
Responsibilities are addressed in the appropriate sections of this procedure.

6.

REFERENCES
OSHA 29 CFR 1910. 119 (e) Process Safety Management of Highly Hazardous
Chemicals Process Hazard Analysis
CPChem Global OE Procedure EHS-6205 Process Hazards Analysis
CPChem Global OE Procedure EHS-6200 Hazard and Operability Study with
Layer of Protection Analysis
CPChem Global OE Procedure EHS-6100 Risk Ranking Matrix
CPChem Global OE Procedure EHS-6206 PHA Facilitator Competency
Assessment

7.

ATTACHMENTS
None

8.

APPENDICES
None

QC-PSM-PRO-00-0001

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