The PHA Recommendation Playbook | Part 2 | Untangling Technical Complexity

Introduction | When “Just Fix It” Isn’t That Simple

July 2025 — by Emily Henry, PE_(SC), CFSE, Functional Safety Group Manager — This blog is the second installment in our PHA Recommendation Playbook series, which is intended to help Process Safety, EHS, and facility managers overcome the common challenges they face when trying to close Process Hazard Analysis recommendations. If you missed Part 1, we explored how staffing and budget limitations create obstacles that can stall even the most straightforward resolutions.

In this article, we’re focusing on a challenge that doesn’t always get the attention it deserves: technical complexity. While some recommendations from a PHA might seem routine at first glance, others involve engineering considerations, system interdependencies, or implementation feasibility that turn them into long-haul capital project efforts. These complications can extend gap closure timelines, inflate costs, and even introduce new risks if not addressed with requisite knowledge and intentionality.

Technical Challenges in PHA Recommendations | What Makes Them So Complex?

Technical complexity refers to the engineering depth, system interdependencies, or feasibility issues that complicate the implementation of PHA recommendations. In industrial environments, this might include design changes that require coordination between multiple engineering disciplines, recommendations that call for feasibility studies, or changes to safety instrumented systems that necessitate revalidation. Sometimes, the complexity lies in hidden system dependencies, meaning that fixing one issue inadvertently introduces another. Compatibility concerns also surface, particularly when legacy systems aren’t designed to accommodate newer technology.

Complicating matters further, many of these challenges aren’t fully apparent during the PHA session itself. A recommendation may seem simple on the surface — “install a relief valve” or “update control logic” — but as the team attempts to move forward with recommendation implementation, the depth of technical complexity becomes clear.

The Compliance Cost of Complexity | What Are the Risks of Unresolved PHA Recommendations?

Delays caused by technical complexity come with consequences. Regulatory expectations require timely closure of PHA recommendations or, at the very least, well-documented justifications for delays. Facilities that fail to address these recommendations in a structured way may face unexpected audit findings, regulatory scrutiny, or even fines.

Beyond compliance, unresolved technical items can increase safety risks. A partially implemented fix or an unaddressed hazard can lead to new vulnerabilities or process weaknesses. From an operational standpoint, unresolved recommendations may lead to unplanned downtime, deferred maintenance, or extended outage windows. Over time, these delays can cause friction between departments and erode trust in the process.

How Should You Navigate Complex Technical PHA Recommendations Internally?

Handling complex recommendations starts with engaging the right people early. Engineering, operations, maintenance, and safety teams must be aligned on what’s practical, what’s required, and what constraints exist. Cross-functional collaboration is essential for identifying implementation barriers before a plan is set in motion.

Conducting feasibility reviews internally can reveal potential problems with space, access, process compatibility, or cost. These reviews don’t have to be overly formal, but they should be consistent and thorough enough to inform the feasibility of implementation of the recommendation at a high level. Documenting known interdependencies also helps ensure one recommendation doesn’t inadvertently conflict with another.

Instead of treating each recommendation as a siloed task, consider how they fit into the broader operational strategy. Iterative planning, where adjustments are made as new information surfaces, can help prevent bottlenecks and avoid over-committing resources.

When Does Technical Complexity Require External Expertise?

There are times when a PHA recommendation goes beyond internal capacity, whether due to staffing limitations or the depth of technical expertise required. Yet not all third-party support is created equal. Some firms deliver a report and walk away, leaving your team with a list of action items and little else in the form of background education.

Working with an experienced third-party can change the dynamic. The right partner doesn’t just identify risks; they help you engineer prioritized solutions that are feasible, effective, and aligned with your facility’s operations. A third-party familiar with system interdependencies can offer practical mitigation strategies that don’t introduce new problems elsewhere.

Execution also matters. A partner that provides project management oversight can track progress, maintain accountability, and deliver documentation that supports audit defensibility. By helping prioritize what matters most and sequencing efforts strategically, an experienced partner can support smarter capital planning and more efficient implementation.

Collaboration with a third-party should never feel like you’re relinquishing control. Instead, it should feel like gaining clarity with a clear line of sight from risk to resolution, with results your team can stand behind.

What Are Proactive Strategies to Minimize Technical Implementation Risks?

Managing technical complexity isn’t only about reacting once a challenge appears. Many of the difficulties associated with implementation can be mitigated through proactive planning.

Three core proactive strategies include:

• Integrating front-end engineering and risk assessment into your safety processes. This helps identify potentially complex recommendations earlier in the lifecycle.

• Flagging technically intensive items during the PHA itself or revalidation workshops, so that additional analysis can be scoped and scheduled.

• Allocating budget and time for follow-up studies, such as feasibility analyses, LOPA updates, or HAZOP reviews, when recommendations involve significant system changes.

Maintaining clear documentation is also essential. It not only aids internal decision-making but strengthens your position during audits or external reviews. Finally, it helps to reframe these efforts not just as compliance tasks but as opportunities to improve long-term reliability and operational resilience of your facility.

From Risk to Resilience | Technical PHA Resolution Isn’t Just a Fix—It’s a Foundation

Facilities that manage technical complexity well don’t just avoid problems, they build stronger, safer operations. When engineering, safety, and operations teams work together to resolve complex PHA recommendations, the resulting improvements often go beyond the immediate fix. Systems become more reliable. Cross-team collaboration improves. Equipment failures and unplanned outages decrease.

Moreover, facilities gain stronger footing in the face of audits or regulatory reviews. Well-documented resolutions with traceability to risk assessments show diligence and intent, both of which matter when follow-up questions are asked.

When resolutions are handled with care, the outcome shouldn’t feel like a temporary workaround. It should feel like progress.

The Takeaway | Moving from Technical Complexity to Technical Confidence

Technical complexity is one of the more nuanced challenges in PHA recommendation resolution. It’s also one of the easiest to underestimate. The surface-level simplicity of a recommendation often belies the engineering coordination, feasibility analysis, and systems thinking required to see it through.

By planning ahead, involving the right teams, and knowing when to seek experienced, third-party expertise, your facility can navigate even the most intricate recommendations without losing momentum. And when you do choose to bring in third-party support, working with a team that understands engineering, project delivery, and compliance can be the difference between checking a box and building something truly defensible.

At its best, technical resolution doesn’t just close a gap, it builds a stronger foundation. From risk to resilience, the path is clearer when the process is collaborative, strategic, and informed.