The short answer is you need to perform PHAs in phases, from conceptual stage, through preliminary and detailed design, and then complete these during the pre-commissioning stages (as mentioned by Bryan). The PHAs build upon each other and the completion of the final phase PHA becomes the Baseline PHA. The tools used change from phase-to-phase, [...]
Before the OSHA PSM standard became official (May 1992), OSHA said that they would not use 3rd party or even first party (internal audits) of PSM against a company, but then they add "initially". When asked by us what this meant, they said the first few years of implementation of PSM; this was to encourage [...]
Firstly, you cannot "write a PSM" .... I'm not even sure what that would be. PSM is a not a document for compliance like some environmental studies. PSM, if done correctly, is a way to run a business. If developed and implemented right, it will control the human factors that control the human error that [...]
The CCPS book clearly states LOPA uses a single cause-consequence pair, the worst combination, for the order-of-magnitude risk estimate. Other methods, especially Fault Tree, are more appropriate to treat multiple initiating events. Many times simply summing the initiating events is not appropriate due to limitations in the simplifying assumptions behind the development of LOPA. There [...]
There is a lot of discussion elsewhere on ALARP (and/or ALARA). However, a company can add too many protection layers and invite shortcuts of one or more of the IPLs over the long-term, since staff are pretty sharp at figuring out when the "plumbing is over-tinked". We advise folks to reach barely tolerable on each [...]
