The PHA Recommendation Playbook | Part 1 | Managing Resource Constraints

Introduction | Compliance in the Face of Limited Teams and Tight Funds

May 2025 — by Emily Henry, PE(SC), CFSE, Functional Safety Group Manager — Welcome to the first entry in our multipart blog series, designed as a guide for process safety, EHS, and facility managers who are in the process of resolving PHA recommendations. Each installment will address one of the most common practical, technical, or organizational challenges faced when closing the recommendation gaps of a PHA study. In part one, we will discuss one of the most frequent hurdles: resource constraints, particularly staff and budget limitations.

PHA Primer

A Process Hazard Analysis (PHA) serves as a mechanism for identifying and mitigating risks in industrial environments. OSHA mandates both initial PHAs and regular revalidations for facilities that handle hazardous chemicals or operate under process safety management (PSM) regulations. The recommendations that stem from these analyses are not optional — they are necessary actions required to close safety gaps and prevent incidents. Yet, the journey from recommendation to resolution is rarely straightforward. Among the most common early challenges are staff shortages and budget limitations, both of which can stall progress and jeopardize compliance.

Staff and Budget Limitations: A Common Roadblock in Resolving PHA Recommendations

Resource constraints, particularly in the form of personnel and budgetary limitations, present persistent barriers to the stewardship and closure of PHA recommendations. These constraints are rarely isolated issues. Instead, they tend to surface across departments and project phases, especially when expertise is scarce, or budgets are tight. In the industrial and manufacturing sectors, managers are often asked to do more with less, juggling compliance deadlines with daily operations.

Delays in addressing PHA recommendations can result in increased exposure to safety or operational risks, missed regulatory deadlines, and a higher likelihood of enforcement actions. The cost is more than administrative; it can reverberate throughout the organization, increasing the potential for incidents and ultimately impacting the bottom line.

Resolving PHA Recommendations with Limited Staff and Technical Expertise

Staffing limitations can significantly hamper the PHA resolution process, especially when specialized technical skills are required. For facilities with high-severity hazards, recommendations often involve complex engineering assessments, equipment modifications, or the implementation of advanced safety protocols. These activities call for experienced professionals, typically engineers, safety specialists, or technicians with niche expertise.

When internal teams lack the required personnel or technical depth, recommendation resolution will certainly lag. The risks are not hypothetical; delayed action can mean extended periods where known hazards lack the necessary layers of protection, increasing the possibility of an unmitigated hazard consequence occurring. Over time, this not only erodes safety culture, but can put the entire operation under scrutiny from regulators, insurers, or even the public.

Dealing with Budgetary Restriction Headaches for PHA Recommendations

Budget limitations can be equally as challenging as personnel constraints. Many PHA recommendations require upgrades or modifications to equipment or investments in new safety systems. When budgets are stretched, it’s tempting to defer or downsize these actions. However, the potential consequences of postponement are rarely minimal.

Financially, the long-term risks can outweigh any short-term savings. Delaying investments in safety may lead to regulatory fines, incident-related expenses, or increased insurance premiums. Facilities that consistently operate with unresolved risks may also face reputational harm if non-compliance becomes public or results in an adverse event. Additionally, legal risks escalate if known issues are a contributing factor in an incident.

Navigating Resource Constraints Internally

Effective management of resource constraints begins with prioritization. Not all PHA recommendations carry the same weight or urgency. By ranking actions based on risk severity and regulatory impact, managers can ensure that the most critical items receive attention first. Tying implementation timelines to budget cycles also helps align resources with compliance needs.

Another best practice involves communicating risk in clear, compelling terms to decision-makers. Presenting the business case for timely resolution — not only as a regulatory obligation but as a risk mitigation strategy — can help secure funding and staffing. In short, thorough planning and a clear understanding of the resources required can empower managers to justify funding requests and advocate for staff allocation in a focused, strategic way.

The Support Advantage: Leveraging Third-Party Partners for PHA Resolution

While many facilities strive to resolve recommendations internally, there are times when third-party expertise can be invaluable. Not all PHA providers offer the same level of post-study support; many simply deliver a report and move on, leaving your team with a daunting list to decipher and prioritize.

Partnering with an experienced provider can offer several benefits. External experts often bring specialized credentials and the ability to mobilize skilled personnel quickly, ensuring that urgent PHA recommendations do not drag on unresolved. A knowledgeable partner can also help optimize budgets by identifying targeted, cost-effective options — often with strategic solutions that can resolve multiple recommendations with one move.  

Furthermore, partnering with an experienced company can support your team in developing practical resolution plans and provide tools, resources, and expert guidance tailored to your facility’s needs. This approach not only reduces the internal burden but positions you as a champion of compliance and safety within your organization — saving time, money, and stress.

Planning Ahead: Proactive Strategies to Mitigate Staff and Budget Limitations

Proactive resource planning can make a significant difference. Integrating anticipated PHA recommendations into annual budgets and resource allocation processes can help ensure that funds and personnel are available when needed. Establishing clear internal procedures for escalating and addressing urgent recommendations helps prevent bottlenecks.

Investing in skill development and cross-training internal staff broadens your facility’s capabilities. These measures collectively strengthen the ability to resolve recommendations in a timely, efficient manner.

Lean Teams, Big Gains: The Benefits of Overcoming Staff and Budget Barriers

Successfully managing staff and budget limitations pays dividends beyond OSHA compliance. Facilities that close PHA recommendations efficiently will see a reduced regulatory risk, enhanced operational resilience, and ultimately, fewer incidents. Cost savings accrue through avoided penalties and proactive safety management, while the organization’s reputation is bolstered by a demonstrated commitment to safety and continuous improvement.

The Takeaway | Limited Resources, Unlimited Potential

Staff and budget limitations do not have to be the challenge that prevents your facility’s PHA recommendations from being resolved. With strategic planning, clear prioritization, and — when needed — the support of a capable external partner, facilities can bridge the gap between recommendations and resolution.

For those facing persistent resource challenges, now is the time to review your internal capacity and consider the value of experienced collaboration. By doing so, you not only safeguard compliance and safety but also lead your organization with resilience and integrity, turning every challenge into an opportunity for growth.

Be sure to keep an eye out for the next article in this series, where we will discuss strategies to prevent technical complexities from slowing your PHA recommendation resolution progress. In the meantime, check out this article on the five facets of an efficient process hazard analysis.