According to Jennifer Leszczynski, EHS manager with Kuraray America, a Process Hazard Analysis (PHA) — the thorough, step-by-step review of chemical and manufacturing plant operating procedures — is essential in a well-planned process safety management program.
But even the most carefully executed PHAs can fall victim to a number of pitfalls, including leaders making bad assumptions, failing to be specific enough in the scenario documentation and using conditional modifiers incorrectly.
Fundamental to avoiding these pitfalls and others, Leszczynski said, is building the most effective PHA team possible.
"If there are too many participants, you will find people are having conversations on the side and not able to catch what you’re talking about," Leszczynski said. "Or you may have people who have good information, but they are not participating because there are just too many people, making it difficult to get all the details."
Having too many people participating in the PHA team can be counterproductive, Leszczynski said during this year’s EHS Seminar held in Galveston, Texas, but having too few team members can be equally counterproductive to a successful end result.
"If you don’t have enough people, you’re not going to have that knowledge to really get to the heart of your scenario. We sometimes say, ‘OSHA requires two people: the person who does the methodology and the person who does the process,’" Leszczynski said. "But we all know from experience that that’s not enough to really understand what the scenario is."
Common to industries across the board, Leszczynski observed, is that there is frequently that "one expert" in any organization who asserts themselves over all other participants, monopolizing the conversation.
"Do you ever have that one person in the room that talks the entire time?" she said. "They fill all the space, and they know all the answers and the other people are simply sitting there."
Another obstacle to optimum communication is not including an operator or process technician on the PHA team.
"If you don’t, you are missing that field knowledge," Leszczynski said. "There’s a difference between knowing what the process is supposed to do and what actually happens in the field. Most people interpret someone knowledgeable with the process to be a process technician who is certified on the process, whether that’s a supervisor or board operator who has that official certification."
Building a Process Hazard Analysis team is a numbers game
Jennifer Leszczynski, EHS manager with Kuraray
In simple terms, Leszczynski said, she considers a process operator to be someone who knows "what happens out there."
"Your technology group knows what it is designed to do," she said. "Your engineer might say, ‘Well, we need to change this temperature for the pressure we’re supposed to get.’ But the operator’s response is, ‘When I do this, I get that.’"
Leszczynski explained that this indicates a gap between what is supposed to happen and what is actually happening.
"There are probably things that are going on that are unknown, and it’s the unknown things that produce hazards," she said. "That’s how discrepancies occur."
A solid PHA team also consists of "people like maintenance specialists, process safety and the person who writes your standard operating procedures who know all the steps and the order in which they are supposed to occur," she said.
So then, what is that most efficient, most effective magic number of people to include on a PHA team?
"Probably about five to seven people," Leszczynski concluded. "It depends on the complexity of your process and what you need. A facilitator with some methodology experience is required. You want that person to have process knowledge, but you want someone else there who has process knowledge, too, because you want to have that conversational back-and-forth."
