Process Hazard Analyses (PHAs) and Hazard and Operability Studies (HAZOPs) are cornerstones of effective Process Safety Management. Yet, even the most well-executed studies can lose their value if a formal closeout process is not done, or even if there is, it needs to be more thorough and well-structured.

Key Takeaways:

  • Effective PHA/HAZOP closeout processes are essential, as up to 30% of major safety incidents are linked to failures in implementing recommendations.
  • Validating, assigning, and tracking recommendations with clear accountability reduces misinterpretation and ensures timely implementation.
  • Management approval requires detailed evidence to align recommendations with company policies and resources.
  • Regular audits and review meetings help maintain progress, help reduce delayed or incorrect implementation of PHA recommendations and reinforce a strong safety culture.

Why Focus on PHA/HAZOP Closeout?

It’s all in the data.

Data shows that many chemical process safety incidents are attributed to failures in implementing recommendations from Process Hazard Analysis (PHA) and Hazard and Operability (HAZOP) studies. According to the Center for Chemical Process Safety (CCPS), up to 30% of major process safety incidents involve gaps in implementing safety recommendations. This statistic underscores the need for a consistent and effective closeout process.

Elements of an Effective Closeout Process:

A. PHA Quality Review

At the end of the PHA Sessions, the quality and completeness of the PHA should be reviewed by either client SMEs or a peer review by another experienced facilitator.
This allows reviewers to confirm if known or expected scenarios from the unit/system were analyzed, whether the scenario makes sense, and check the PHA output against internal PHA standards.
Companies may see this as another time sink, but in my experience, the benefits outweigh the perceived hassle. The goal is to ensure that we utilize the collective experience and knowledge of SMEs to ensure the quality of the PHA.

B. Recommendation Validation

Ensure that each recommendation is technically feasible and addresses the risk identified. This step often involves operations, engineering, and subject matter expert teams working together to review and validate solutions.

The recommendation should be as specific as possible and actionable to avoid the potential for misinterpretation but still allow the team options for other solutions that provide the same risk reduction or eliminate the event (consequence).

This review period is the time to ensure there are no factual errors by doing all due diligence work before we present the recommendations to management.

C. Action Assignment and Tracking

Assign each action item to a specific individual or team with precise deadlines and accountability.

There is no reason not to use a formal electronic tracker. Excel spreadsheets go a long way.

D. Management Review and Approval

This is where we get management’s support on the recommendations. Therefore, a management or leadership team review is necessary to get approval from senior management to ensure alignment with company policies and resource allocation.

It’s best to come prepared with all the details to support your recommendations. The goal is to clarify that the recommendation is necessary to reduce or eliminate a scenario risk and ensure everyone is on board.

Examples: Include photos of inspection of equipment with heavy corrosion, calculations to back up a reverse flow and overpressure scenario, Google Maps snippets highlighting locations where people tend to loiter when they are not supposed to, which increases potential exposure, and so on.

E. Quality Assurance Audits

Set periodic audits to verify that recommendations are being implemented (is there movement) and, for those implemented, if they have been implemented correctly.
This means setting cadence meetings to review all recommendations from PHAs within a consistent schedule that depends on the size and capabilities of the site.
Many platforms in the industry have automated reminders to ensure the organization can stay on top of the recommendations.

Still, even a simple calendared cadence meeting already adds value and helps ensure the progress of the recommendations.

Industry Incidents Related to PHA Recommendation Closeout:

I’ve listed below some key industry incidents that happened due to improper PHA and how each of the listed elements could have helped prevent the incident:

McKee Refinery Propane Fire (2007)

A PHA had recommended installing remote shut-off valves, but this recommendation was not implemented. During a fire, operators could not isolate fuel sources remotely, leading to a larger incident. This highlights the critical importance of following through on PHA recommendations.

Richmond Refinery Fire (2012)

The Chemical Safety Board investigation found that Chevron had failed to implement more effective preventive recommendations from previous PHAs. Corrosion SMEs were not involved in the PHA and if a proper review of the PHA was done with the SMEs at closeout, perhaps the need to do a 100 percent component inspection of high-risk carbon steel piping or upgrading susceptible piping to an inherently safer material of construction in the unit could have been raised and an appropriate recommendation developed.

Anacortes Refinery Explosion (2010)

Investigations revealed that previous hazard analyses had identified the potential for catastrophic failure of heat exchanger components but failed to recommend effective safeguards. This demonstrates the importance of not just identifying hazards but also ensuring robust recommendations are made and implemented.

The Benefits Are Clear: Reduced Incident Rates: Companies with diligent PHA closeout processes have reported up to a 40% reduction in process safety incidents, according to a CCPS benchmarking study.

Improved Regulatory Compliance: Proper documentation and follow-through ensure compliance with OSHA and other regulatory requirements, avoiding costly fines and penalties.

Enhanced Safety Culture: A rigorous closeout process demonstrates the company’s commitment to safety, reinforcing a culture where safety is prioritized and valued.

PHA/HAZOPs shouldn’t just end with a report. They should trigger meaningful actions that translate into safer operations and fewer incidents. As professionals in the field, we are responsible for prioritizing the closeout process and ensuring that our safety efforts make a difference.

What strategies does your organization use to ensure PHA recommendations are effectively implemented?

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