Effectively Addressing New PSM/RMP Damage Mechanism Review Requirements with an Integrated PHA (iPHA)

Since August 2012, significant changes have been proposed by a number of agencies to Safety Management Systems (SMS) Programs, e.g., Process Safety Management (PSM), Risk Management Programs (RMP), and related SMS Regulatory Requirements. Many of these are framed within OSHA's and EPA's PSM/RMP Modernization/Expansion Programs, and key technical and regulatory changes are being proposed by Federal OSHA, U.S. EPA, Chemical Safety Board (CSB), California Office of Emergency Services (OES), and other agencies. As part of these SMS Regulatory Program Modernization Initiatives, on October 31, 2014, Cal/OSHA issued the latest update to its proposed regulation for "Process Safety Management for Refineries" in response to a report from the California Interagency Refinery Task Force. A number of these modernization initiatives have focused on perceived weaknesses in the application of the Process Hazard Analysis (PHA) and Mechanical Integrity (MI) elements of PSM/RMP. The main objective of this paper is to provide some tangible suggestions for effectively addressing proposed changes associated with Damage Mechanism Reviews (DMRs), with the intent of providing straightforward tips for owner/operator companies to address contemporary best practices and to minimize the effort associated with later upgrades to various PSM/RMP Program elements, once these proposed initiatives become regulatory requirements. The core of this paper will detail a Streamlined DMR approach to address near-term objectives and an Integrated PHA (iPHA) approach to address long-term objectives by harmonizing PHA and MI efforts. Key topics include: