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Updated April 2026 - We can help you pick up your PHA/LOPA which maybe been put to the side and provide the services to set you up for the safety system design phase. Standard SIS deliverables include the review of specification, confirming that the SIL levels are what they should be, and that the proof testing procedures are correctly documented to support your regular testing intervals.  Transcript: "aeSolutions has a full suite of offerings and the safety lifecycle, from the PHA LOPA aspect in the upstream design all the way through into the detailed engineering phase. Our group SIS engineering (Safety Instrumented Systems) sits kind of right in the middle between the two, you have the PHA LOPA upstream and you've got the detailed design downstream. We take what the PHA LOPA outputs. We massage it a little bit to get it into a more meaningful list of safety functions, for example. And then we can take that through the conceptual design phase where it goes into SIL calculations and SRS's and cause and effects and gets that into a into a package that can ultimately be handed downstream into the design phase. Everything we do here is developing standard SIS deliverables by making sure that all the specifications are correct. All the safety integrated levels are what they should be. All the proof testing procedures are correctly documented. So that our clients can have regular testing intervals with the necessary equipment that they need to be testing. One of the things that we've seen a lot of our clients do is they'll do the PHA LOPA and then they'll take that information and they'll essentially file it away and do very little else with that. And one of the challenges that we've seen is the SIS needs to be designed against that document and so we can take that document either from an internal study or from a client and help pick it up and do the rest of the upstream engineering on it. Where we identify, what are your safety functions look like, how many sensors o you have? And get that into a more defined safety function that can ultimately be? Hand it off to the design team. The other aspects that we run into is a lot of times I'll do the front end engineering all the way through. You know, for example an SRS data sheet, but then they don't do things with it and ultimately the intention behind that is not only to use as an operating manual for your safety function, but you also want to use that as the guiding document in the design phase so that you ensure that everything that you're doing in the design. This matches what you intended it to do on the on the front end."    PHA LOPA Process Safety

by Keith Brumbaugh , P.E., CFSE ​ Achieving Safety Integrity Level (SIL) targets can be difficult when proof test intervals approach turnaround intervals of five years or more. However, some process units have planned and predictable unplanned shutdowns multiple times a year. During these shutdowns, it may be possible to document that the safety devices functioned properly. This can be incorporated into SIL verification calculations to show that performance targets can now be met without incorporating expensive fault tolerance , online testing schemes, etc. This can result in considerable cost savings for an operating unit. The problem If a process plant is following the ANSI/ ISA 84.00.0 1 process safety lifecycle (i.e. ISA 84) or similar, as part of the allocation of safety functions to protection layers phase, a SIL assessment (e.g., a Layers of Protection Analysis (LOPA)) would be undertaken to assign Safety Integrity Levels (SIL) targets to a Safety Instrumented Function (SIF) . A scenario could occur in the design and engineering phase of the ISA 84 safety lifecycle when performing the SIL verification calculations, that the team discovers the SIFs do not meet their performance target. Assuming the calculation was done properly using valid data and assumptions, something would need to change in order to meet or exceed the required performance targets. This issue could occur in a Greenfield plant when first designing a SIF, but is more likely to be discovered during a revalidation cycle of a brownfield plant. Click here to view the complete whitepaper

Updated April 2026 - Written by aeSolutions Technical Team - Some companies implement intermediate tasks during the analysis and design stages of an IEC/ISA 61511 Lifecycle Project with names such as “IPL Select” or “ LOPA Reconciliation”. The result of such studies is often a “refinement” of the control and/or safety system. Examples have ranged from identifying additional final elements to avoid the hazard, eliminating the use of shared instrumentation between protection layers, addressing response time issues, and assessing control system protection layers for full independence of a function against the initiating event and other protection layers. The benefit of such studies is that it’s easier and less expensive to make necessary changes to systems while the design is still on paper. It’s very expensive, and in some cases not even possible, to make design changes after systems have been installed. In the end, it all boils down to people. It is imperative that all personnel be competent in their roles within the Safety lifecycle. New people entering the industry need an opportunity to learn. Yet they need training, mentoring and reviews of their work in order to prevent systematic failures from creeping in and causing accidents. To read more examples of systematic failures throughout the lifecycle , and to learn how to reduce them, read the full paper “Methodologies in Reducing Systematic Failures of Wired IPLs” . Process Safety & Risk Management Industrial Safety Instrumented Systems

by aeSolutions Technical Team & Tab Vestal ​ Updated April 2026 - The history of high consequence incidents in industry reveals that most accidents were the result of systematic failures, not hardware failures. However, a higher degree of focus in engineering is often on the quantifiable failures of hardware. Process Safety risk gaps are often closed or reduced by several types of Independent Protective Layers (IPLs). Two common types are Safety Instrumented Functions (SIFs) and Basic Process Control System (BPCS) functions. The SIFs typically reside within a SIL-rated programmable logic controller, and their achieved quantitative performance is calculated based on random hardware failures of the SIF hardware components. Conversely, BPCS protective layers are assigned generic industry-accepted probability of failure credits. The BPCS generic industry-accepted probabilities of failure are conservatively assigned and consider unquantifiable human-induced systematic failures. In either case, the likelihood of systematic failures can be reduced by recognizing design, specification, maintenance, and operations activities that are potential sources, and applying measures to prevent or reduce them. By reducing systematic failures, you reduce the risk in the industrial process and increase confidence in meeting the intended integrity requirements. This technical paper will discuss the common sources of systematic failures and preventative or mitigative measures to prevent their occurrence. Topics Included in Whitepaper: Systematic failure , random hardware failure , Independent Protective Layer, IPL, SIF, SIS, BPCS , common cause, Human Factor Analysis , SIL Verification Click here to view the complete whitepaper

Updated April 2026 - Those who work in high hazard industries are familiar with the OSHA Process Safety Management (PSM) requirements for routine Process Hazard Analyses (PHA) for their processes. Hazard and Operability (HAZOP) and Layer of Protection Analysis (LOPA) are recognized methods for PHA. LOPA is widely used as a semi-quantitative method to identify, assess, and improve the most effective safeguards for higher consequence scenarios identified in a qualitative HAZOP study . One of the important products of a LOPA is a list of Independent Protection Layers (IPL) . When correctly identified, IPLs are devices, systems, and actions that are capable of preventing a hazard scenario from proceeding to the undesired consequence. In layman’s terms, they are the “best” and most effective of the safeguards that were identified in the HAZOP for specific scenarios and initiating events. The core attributes for safeguards to qualify as IPLs are well-known and have criteria including: Independent of the initiating event and of other protection layers Specific to the hazard Functional, dependable, and reliable (including routine testing) Auditable Secure Subject to management of change There are many reputable sources for training for the HAZOP and LOPA methods. Many organizations also have good internal guidance on this subject. But what happens when inadequate guidance, training, or discipline for the correct use of LOPA and identification of IPLs is present? You might be surprised at how often safeguards not meeting the core attributes are specified as IPLs in industry. It’s easy to find advice detailing the complexities of proper IPL selection and management, but without a facilitator well-versed in the basics of IPL selection, LOPA teams can get off on the wrong foot. The Challenges Many companies and LOPA practitioners employ excellent practices to identify and validate IPLs during LOPA. However, it is surprisingly common for significant IPL selection errors to be encountered during externally facilitated revalidation PHAs, audits and other types of process safety reviews. IPL concerns of the following types are entirely possible to occur in LOPA studies if initial selection or follow-up IPL validation is not as it should be: Use of two or more relief devices, all taken with two or more IPL credits. Relief devices are often a highly effective safeguard. However, they are subject to concerns that should limit the credit taken at times, including use in services where "pluggage" or other common cause failures are credible, engineering assumptions on sizing are not as the PHA team assumed, poor-quality or no routine inspections are performed, and other issues. Use of instrumentation whose failsafe failure modes are opposite of that assumed by the PHA team, which may result in an unrecognized IPL failure to the dangerous mode. Selection of one facet of an IPL such as a BPCS alarm, without recognition that other facets are also needed for a complete IPL, such as alarm prioritization and management, training in the specific alarm response, an operating procedure, and proper field instrument functional testing. Selection of a BPCS alarm and Operator response as an IPL, without confirming that sufficient time is present before hazard development to evaluate and respond effectively to the alarm. Selection of IPLs with insufficient independence from the initiating cause of a hazardous scenario, or insufficient independence from another IPL for the same scenario. A classic example of this is selection of an instrument to alarm or interlock of a process condition that could be initiated by a failure of that same instrument. Crediting design pressure and temperature ratings; both are equipment attributes that should normally be taken into account in identifying the scenario consequences, not credited as an IPL. Building Confidence Improperly selected and validated IPLs can result in high hazard scenarios that have far less risk reduction in place than you think you have. Implementing a systematic process to properly vet your IPL candidates for the core attributes is strongly recommended. Engaging experienced PHA/LOPA facilitators and having the right team during the meeting is the first step in proper IPL selection. Further validation of IPLs to confirm they meet the defined criteria can be time consuming but also goes a long way toward increasing your confidence in your most important safeguards for higher consequence scenarios in highly hazardous chemical processes.

Updated April 2026 — Authored by Carolyn Bott — A Process Hazard Analysis (PHA) will prove to be the cornerstone of Process Safety Management (PSM) at any operating facility with the correct tools and the right leaders. Although there are many variables concerning PHAs, the process can be simplified and impactful results can be attained. In this blog, we delve into the 5 facets of an efficient process hazard analysis (PHA). Process Hazard Analysis Scope A well-defined scope for a Process Hazard Analysis is critical to identify potential safety and environmental hazards in a facility. Having a clear and defined Process Hazard Analysis scope does the following: Sets the boundaries of the analysis - This assures all necessary elements are included and relevant risks are identified and assessed Enables the Process Hazard Analysis team to focus on specific areas of concern and analyze them in detail - This reduces the potential for error and minimizes both the time and resources needed Ensures that all stakeholders are aware of the objectives and outcomes of the PHA Standard for Approaching a Process Hazard Analysis Different companies may have their own specific Process Hazard Analysis standards, specific to their operations and the risks involved. These standards typically outline essential measures to perform a thorough PHA, including: Qualifications and training required for team members Selection of appropriate methodologies Level of detail required in the analysis Documentation requirements for the study Frequency of review Ongoing monitoring requirements ensuring the safety and efficiency of operating processes Adherence to these standards is typically required by regulatory bodies and industry best practices. A standard can ensure all relevant factors are considered and a thorough analysis is conducted. Following a standard also facilitates communication and collaboration among stakeholders, enhances consistent decision-making across sites, and promotes continuous improvement in a site’s process safety. Process Hazard Analysis Team An effective Process Hazard Analysis team is composed of individuals with diverse expertise, including engineers, operators, maintenance personnel, and safety professionals. The team: Shall have expertise in engineering and process operations Shall include at least one employee who has experience and knowledge specific to the process being evaluated One member of the team must be knowledgeable in the specific process hazard analysis methodology being used Must be able to work collaboratively to identify hazards, evaluate risks, and develop appropriate risk management strategies Effective communication and teamwork are vital for a successful and efficient PHA. The proficiency of the PHA leader or facilitator has a substantial impact on the team and the outcome of the PHA. A facilitator leans on their own risk management experience and is responsible for guiding the team through the identification and evaluation of all credible process hazards. The leader continuously assesses the team’s dynamic and intervenes when necessary to ensure the group remains on task to complete the PHA efficiently with impactful results. A company can utilize in house experts or hire a third-party to shepherd their Process Hazard Analysis needs – Process Safety Consulting Process Hazard Analysis Techniques & Tools Methodologies The methodology selected must be appropriate to the complexity of the process and site standards. One or more of the following methods, as appropriate, may be used to determine and evaluate the hazards of the process being analyzed: What-if Checklist What-if Checklist Hazard and operability study (HAZOP) Failure mode and effects analysis (FMEA) Fault tree analysis An appropriate equivalent methodology For more info on choosing a risk assessment methodology, check out our webinar that examines the advantages and limitations of various methodologies: Choosing a Risk Assessment Methodology Tools Computer-based systems are used to document Process Hazard Analysis discussions in an organized manner and provide consistency throughout the analysis. Examples of PHA documenting software include: Sphera® PHA-Pro® PrimaTech PHAWORKS RA® aeShield® aeFacilitator® Using appropriate software eases the execution of risk studies. Process Hazard Analysis Review Cycle All Process Hazard Analyses must be updated and revalidated every five years. The periodic review should reflect any changes in the process or surrounding environment that may impact safety. An alternate approach to managing PHA updates is to incorporate them into the study file as changes occur. This method is often called an Evergreen PHA or Continuous PHA Revalidation. An efficient and effective PHA can enhance the safety of processes, reduce the risk of accidents and incidents, improve compliance with regulations and standards, and ultimately support the organization's goals and objectives. Ensuring these five (5) components are in place can help companies have an efficient PHA to identify and mitigate risks before they become safety incidents. The Takeaway | 5 Facets of an Efficient Process Hazard Analysis Summarized Clear and well-defined scope that is relevant to the system being analyzed Systematic and structured approach Multi-disciplinary team of subject matter experts who can identify and evaluate potential hazards from different perspectives Use of appropriate techniques and tools to evaluate and prioritize risks Periodic reviews and updates If you need more guidance for your Process Hazard Analysis, please feel free to reach out to aeSolutions to speak with one of our PHA experts about our capabilities. Click here for more information on aeSolutions' HAZOP Study services

What’s a HIPPS and where are they used? Updated April 2026 - There are two common applications for a High Integrity Pressure Protection System (HIPPS) . First, many process facilities have expanded to the point where the original pressure relieving and flare system may no longer be able to handle a potential event. Preventing a potential overpressure through the use of a HIPPS can be done at a much lower cost compared to installing a new flare and header system. Second, many subsea and land based pipelines are not designed to withstand full wellhead pressure. So a HIPPS measures pressure (usually using redundant transmitters), utilizes a logic solver (many technologies and configurations are acceptable), and closes valves. While such designs are allowed per current codes, the justification of such a system requires careful analysis by a team of specialists. The justification and analysis of a HIPPS must consider all operating and upset conditions that might cause an overpressure. Process dynamics must be analyzed to determine if the HIPPS can respond quickly enough to prevent the hazard. Some cases may be quite complex with multiple scenarios and multiple HIPPS. Without an adequately sized conventional relief system, the HIPPS represents the last line of defense against an overpressure event. Subsequently, many end users require an independent, third party review of the justification of such a system. How good is good enough? A HIPPS should offer performance as good or better than the conventional relief system it may be replacing. The performance of relief valves in the process industries varies considerably depending upon the application. Published sources of data show that relief valves in some applications offer performance no better than the equivalent of Safety Integrity Level 1 (SIL 1). Considering the uncertainty of the data, many specify that HIPPS meet SIL 3 performance. This requires the use of fault tolerant sensors a nd valves. The use of a SIL 2 system is still a possibility, with significantly lower capital and operational costs. Questions to ask yourself Do you have a case where the existing relieving system is unable to adequately handle the load, and has this been documented in a thorough hazards analysis? Is the vessel in air, water or steam service? (If yes, the use of a HIPPS is not permissible.) Is approval of local authorities required? Do you have a case where a pipeline is not rated for the full wellhead pressure? Have you performed a SIL selection study to determine the level of performance that will be required by the HIPPS? aeSolutions is here to help aeSolutions can help you determine whether a HIPPS is a viable option for your application. If justified, we can work with you to develop the requirements specification and deliver a system that will meet your specific safety and cybersecurity needs. #HIPPS Click here for more information on aeSolutions' pressure relief study services

By Chris Hickling Updated April 2026 - A Fire & Gas System (FGS) philosophy provides a solid foundation for the design of an effective gas detection system, which in turn helps protect plant and personnel from gas releases and resulting flammable and/or toxic effects. An FGS philosophy for a process facility that is not fit for purpose or does not have a firm auditable basis can increase the likelihood of undetected leaks incurring risk to personnel or unnecessary expenses for the company. Under-engineering a gas detection system has safety implications, while over-engineering has commercial implications such as increasing capital and maintenance costs without significantly reducing risk. The workflow for an FGS philosophy can be summarized in the following steps: Assess FGS requirements – review regulatory requirements, corporate standards, pertinent Process Hazard Analysis (PHA) recommendations, and Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) Develop FGS philosophy and procedures – review materials and properties (flammable, toxic, or inert), process flow, and risk tolerance criteria Define FGS scenarios and zones – determine hazards using data for process conditions, weather, occupancy, and airflow data, and drawings such as plot plans, Piping & Instrumentation Diagrams (P&IDs), and Cause & Effects (C&Es) Define zone FGS performance requirements – Develop criteria to assess facility layout and define areas Develop criteria for FGS detector placement What makes an effective FGS philosophy? Firstly, it's important to establish the scope of the FGS system. Is it intended to protect on-site personnel and equipment, offsite community, and/or environment? A comprehensive review of the entire facility is essential – if individual process units at the facility are exclusively analyzed for gas detection, it could result in a fractured response and unforeseen effects at other units. A gas cloud doesn't care where it's released or where it's going, and it doesn't respect boundaries. Secondly, the FGS philosophy should follow applicable codes like NFPA 72 and be applied consistently across the facility. Issues could arise if different areas of the plant use different gas detection technologies or alarm levels; for example, if one unit of the plant alarms at 10% of the Lower Explosive Limit (LEL) and another unit alarms at 20% LEL, or there are inconsistent color of warning strobes for a toxic gas release. Consistency in gas detection, alarms, and encompassing standardized procedure(s) helps the operators and employees respond efficiently. Additionally, the FGS philosophy should lay down the criteria for decisions on gas detection required and appropriate mitigative response such as alarm levels (e.g., alarm at 10% LEL). The FGS philosophy also helps decide the voting criteria for the number of gas detectors to take action. For example, two out of two (2oo2) gas detectors may be required to alarm before starting the sprinkler system or dumping Halon. Finally, an FGS philosophy should be auditable. During its development, assumptions are made which feed into how the gas release is modeled and location of gas detectors. If a bad assumption is made and a leak later occurs, it is essential to be able to revisit the original FGS philosophy and assess the original basis for the design. If the gas detection system has a performance-based design, the layout of the system is documented so that it can be reviewed and adjusted. Traditional rules of thumb gas detector placement do not offer this ability to review and update the basis. Once these practices are incorporated into a facility's FGS philosophy, a comprehensive and well-documented FGS philosophy provides a solid foundation for the design of an effective and auditable gas detection system. Facilities can have a dependable basis to ensure an appropriate number of gas detectors in the appropriate locations, potentially lowering risk and minimizing costs for the gas detection system. Click here for more information on aeSolutions' SOP Training and Development services

Understanding a Dust Hazard Analysis (DHA) Updated April 2026 - Following on from the first four aeSolutions blogs on the subject of combustible dust concerns , this blog provides another deep dive into the topic. We previously addressed the basic concerns around combustible dusts, many of the standards that address dust hazard guidance , and the properties and testing for combustible dusts ; potential ignition sources ; and potential safeguards . This article will build on those topics to pull it all together and review a commonly used dust hazard analysis (DHA) method. The Challenges | Dust Hazard Analysis (DHA) A Dust Hazard Analysis or DHA is an important method to assess the risk posed by ignition of combustible dusts. Companies handling highly hazardous chemicals (HHC) routinely conduct process hazard analyses (PHAs), but it is not common to encounter PHAs that thoroughly review combustible dust hazards or company internal standards that address combustible dust hazards. Many companies’ PHAs do not address combustible dust hazards in an organized manner or in a manner that complies with industry guidance on dust hazard analyses (DHA), if the dust hazards are reviewed at all. Why Would You Conduct a Dust Hazard Analysis For a Combustible Dust Process? There are several reasons, and the most obvious is to protect people, the environment, assets, and reputation from dust explosions and fires. Other reasons for a Dust Hazard Analysis (DHA) include: The OSHA general duty clause requires that, in addition to compliance with hazard-specific standards, all employers provide a work environment " …free from recognized hazards that are causing or are likely to cause death or serious physical harm. " A company may identify the need for a Dust Hazard Analysis on an existing combustible dust process internally due to this requirement. A dust explosion incident involving a dust with identical or similar properties to that in an existing process may occur. An industrial hygiene review of process dust or particulates may identify combustibility concerns. A PHA team may identify the need for a deeper dive into dust risks. A codes and standards review may identify NFPA 652 (Standard on the Fundamentals of Combustible Dust) as a needful standard for compliance. NFPA 652 is considered to be a Recognized And Generally Accepted Good Engineering Practice ( RAGAGEP ). An insurance company providing coverage for the facility may request it. How to Conduct a Risk-Based Dust Hazard Analysis A Dust Hazard Analysis is a focused method to improve facility safety by identifying combustible dust hazards and necessary safeguards associated with a process. There are variations across companies on how DHAs are conducted, similar to the many variations on PHAs that can be found in industry, but there are two basic approaches: a traditional approach based on an engineering analysis and standards compliance; and a risk based approach. Most companies opt for a risk-based approach and those basic steps are described here: Identify the relevant properties of a combustible dust (as described in part 2 of this series). Form a suitable team to perform the Dust Hazard Analysis, including a qualified facilitator. Determine which internal and industry standards apply to the Dust Hazard Analysis and educate team members on those standards. (There is a partial list of applicable industry standards in part 1 of this series.) Assemble or develop the process safety information that the Dust Hazard Analysis team will need, including equipment ratings, electrical area classification designations, dust data, safe operating ranges, operating procedures, housekeeping protocols, and current maintenance regimes, among other data. If there are existing mitigating safeguards (as described in part 4 of our Dust Hazard Analysis series ), data on those systems should also be readily available. With guidance from a qualified facilitator, the team develops the credible dust cloud and dust layer scenarios internal and external to the equipment. The team identifies the credible internal and external ignition sources for each scenario (as described in part 3 of our Dust Hazard Analysis series ). The team then assumes that an ignition occurs in each scenario and assesses and describes the potential unmitigated safety and environmental (and sometimes commercial and reputational) consequences. Guidance from a qualified facilitator is crucial at this step. The team then assesses the likelihood of occurrence of the credible ignition sources. Guidance from a qualified Dust Hazard Analysis facilitator is also crucial at this step. Risk ranking results and acceptance criteria vary from company to company, but typically the team then uses the consequence and likelihood to develop an unmitigated risk rank for each scenario. The team then assesses existing preventive and mitigating safeguards for each scenario, using those factors to determine the existing mitigated risk rank for each. When the mitigated risk ranking does not meet the risk criteria set by the company, then the team typically develops recommendations for additional engineering and/or administrative safeguards. The team may also need to issue recommendations to ensure that safeguards have sufficient specificity, independence, dependability, and auditability, similar to Layer of Protection Analysis (LOPA) independent protection layers , if that is a company expectation. Finally, the facility follows up on the Dust Hazard Analysis (DHA) recommendations. If this process sounds a great deal like a HAZOP study to you, then you are right on target. It is also a common practice for companies to adapt their LOPA methods to be suitable for Dust Hazard Analyses for the higher consequence scenarios. It is generally a feasible task to adapt or develop HAZOP and LOPA software templates to be suitable for DHAs. It can even be done in spreadsheets or word processing documents in case of need, though this type of documentation is a little more difficult to initially develop. An excellent reference for those who wish a deeper dive into DHA methods is Guidelines for Combustible Dust Hazard Analysis , 1st Edition, 2017, by Center for Chemical Process Safety, published by Wiley-AIChE available on-line from your favorite technical bookseller. The Risk of Dust Hazards Do you handle potentially combustible dusts at your site? It is difficult to adequately control a hazard that is not well-understood. Even if you have a good-quality PHA, it may not delve deeply enough into the combustible dust topic in accordance with NFPA 652. NFPA 652 states that existing processes and compartments (e.g., building compartments) shall have a completed DHA by September 7, 2020 (¶ 7.1.1.2) and that the Dust Hazard Analysis shall be reviewed and updated at least every five years (¶ 7.1.4). Are you in compliance? Are you positive your site is managing its combustible dust risks in all phases of operation well enough to prevent a serious explosion? The Takeaway - Dust Hazard Analysis (DHA) If you have not previously taken a deep dive into the combustibility properties of your particular dust(s) and completed a Dust Hazard Analysis at your site, now would be a good time to do so. If you do not have the right expertise in your staff to assess dust hazards, consider engaging a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables assessors to share the general and specific methods proven to minimize dust explosion hazards across industry. This independence from the site and company has the best probability of a careful analysis with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards. Written by Judith Lesslie, CFSE, CSP AIChE Webinar: Combustible Dusts and Dust Hazard Analysis: Assess Your Risk presented by Judith Lesslie - Senior Principal Specialist - aeSolutions

by Judith Lesslie, CFSE, CSP Updated April 2026 - Those who work in high hazard industries are familiar with the OSHA Process Safety Management ( PSM ) and EPA Risk Management Plan (RMP) requirements for routine audits to assess and verify compliance with these regulations. In a prior blog, we reviewed different strategies for accomplishing these audits. In this blog, we will cover specific types of concerns that have been identified at many manufacturing sites. The Challenges Companies conduct audits in order to assess the effectiveness of their process safety systems, with the primary goal of ensuring their covered processes are managed in a way that minimizes the risk of process safety incidents. In a review across many manufacturing segments, company, and site PSM and RMP audits, it has been found that the same types of concerns are present at many locations. These areas of concern occur across the entire range of PSM and RMP elements. In Part 1 we discuss PSM/RMP applicability, Employee Participation, Incident Investigation, Contractor Management and Hot Work, Emergency Response and Audits: In the area of PSM and RMP applicability , it is important for sites to assess and document their inventories of highly hazardous chemicals (HHC), keeping in mind that the PSM and RMP HHC lists are not identical. In a related vein, failure to analyze HHC inventories near occupied buildings and failure to completely assess interconnectivity of potentially covered process equipment can be serious concerns. Employee Participation is an important element of compliance. While most sites have a reasonable level of employee participation in their process safety programs, that participation is often not described in a procedure or road map. This represents a missed opportunity to document participation and to educate site personnel on their opportunities to get involved in process safety activities. Sites often have a one-size-fits-all Incident Investigation method, which may be either too simple or too complex for some incidents; this leads to the potential for missed root causes that need to be addressed or to spending too much time and effort on less severe incidents. Allowing for a range of investigation methods depending on the actual and potential severity of an incident is an excellent practice to consider. Management of Contractors is typically reasonably good across sites, with the possible exception of failure to consider past performance of contractors in ongoing selection processes. A process to define acceptance criteria and to assess past performance of contract firms via review of their OSHA logs is sometimes found to be a concern. One would think that compliance with the Hot Work element would be simplest of all since the requirements are clearly and prescriptively outlined in OSHA 29 CFR § 1910.252. Two of the most frequently identified concerns for this element are failure to maintain or document a fire watch present for 30 minutes after any welding or cutting operations. The other is failure to post additional fire watches on multi-level worksites where falling sparks may be a concern or conduction, or radiation may pose a concern to combustibles that cannot be removed or protected. Emergency Response is an area where the PSM and RMP standards diverge to some extent, including the distinction between offensive and defensive responders. Compliance with the PSM Emergency Response element is relatively straightforward and largely covered in 29 CFR 1910.38 - Emergency action plans. Where concerns are more often identified is in the RMP Emergency Response element, where the outward-looking activities are not always in perfect order. For example, all affected public receptors may not be identified and documented in the site emergency procedures, and/or the contact information for those receptors may not be tested on a regular basis. While not specifically a PSM or RMP requirement, the incident management plans for some companies do not take advantage of structuring their incident management systems in accordance with the National Incident Management System (NIMS); there is valuable free training offered through FEMA which will qualify site personnel to act in standardized ICS roles and enable good coordination with outside agencies in the event of a serious incident. Audits are deserving of their own blog article ( which you can find here ). The most common audit element theme found at various facilities is an audit that does not dig deep enough into process safety programs and into the evidence of execution of each program element. Audits are overdue more frequently than you might anticipate as well. When a good-quality periodic audit with actionable recommendations is executed, that is not the end of the process. The recommendations or actions from that audit then need to be tracked to completion and documented as complete in a reasonable period of time, and that is unfortunately lacking at a variety of facilities. The Stakes The PSM and RMP regulations have proven over time that they are excellent practices to drive the reduction of serious process safety incidents. It is far better for a company and sites to find and correct their own PSM and RMP system deficiencies than for a serious incident to occur or for a regulatory agency to identify it. Are you positive that the commonly found concerns reviewed above are not present at your facility? So What? If you have not previously taken a deep dive into the assessment of the topics above at your site, now would be a good time to do so. If you do not have the right expertise in your staff to assess PSM and RMP compliance in these areas, consider selecting a process safety consultancy with deep experience and expertise to assist you. Their range of experience enables external auditors to share the general methods proven to drive good PSM and RMP compliance across industry. This independence from the site and company has the best probability of a careful assessment with fresh eyes on the relevant critical systems and leads to more efficient compliance with the necessary standards. Click here for more information on aeSolutions' PSM & RMP Audit Services In Part 2 will include a review of common deficiencies in the elements of MOC/PSSR, Process Safety Information, Operating Procedures, Mechanical Integrity , Process Hazard Analysis, and Training.

Updated - April 2026 - The ISA/IEC 61511 Safety Life Cycle starts with a Process Hazard Analysis (PHA) and a Risk Assessment. What is a PHA? Why do we do it? =================================================== Excerpt taken from the webinar: Choosing a Risk Assessment Methodology In the full recording the ANSI/ISA 61511 Safety Life Cycle is shown to start with a Process Hazard Analysis (PHA) and a Risk Assessment. This was the first webinar of our 3 part series and details the purpose of Risk Assessment and examines the advantages and limitations of various methodologies including Risk Graph, Layer of Protection Analysis (LOPA), Quantitative Risk Assessment (QRA) , and others. See all our full recent webinars on https://www.aesolutions.com/webinars As a supplier of complete process safety and risk management solutions, we pride ourselves on providing engineers from industry with design, maintenance, operating, and process safety backgrounds. Our specialists understand how plants operate because they have actually worked in covered processes and facilities. Learn more-- https://www.aesolutions.com/process-s...

December 2024 - Learn about six hidden pitfalls that undermine workplace safety culture and learn actionable strategies to foster a more resilient and safety-conscious environment. This article explores the following topics and more: Click here to read the full article on IEN.com Applicability of Process Safety Management (PSM) and Risk Management Program (RMP) Regulations : Many facilities neglect to assess whether these regulations apply to their operations, leading to unstructured safety processes. Mechanical Integrity : While fixed equipment like vessels and piping are usually well-managed, issues frequently arise with rotating equipment and control systems due to inadequate monitoring and maintenance. Management of Change (MOC) : Organizations often fail to implement robust MOC procedures, resulting in unassessed risks when changes occur in processes or equipment. Operating Procedures : Outdated or poorly documented operating procedures can lead to unsafe practices and increased risk of incidents. Training and Competency : Insufficient training programs contribute to a workforce that is ill-prepared to handle safety challenges effectively. Incident Investigation : A lack of thorough incident investigations prevents organizations from learning from past mistakes and implementing corrective actions. by Judith Lesslie, CFSE, CSP, CCPSC , Senior Principal Specialist at aeSolutions . Read the full article here: Safety Culture: Examining Common Shortcomings - IEN.com