Believe it or not, a hazard assessment is totally different than a process hazard analysis. The PHA is a team activity aimed at identifying and mitigating risk in the system, whereas the hazard assessment is a detailed and technical report of the worst-case and alternate case release scenarios. While the requirements are quite extensive, here is a summary of Title 40 CFR Part 68 Subpart B:
The hazard assessment section outlines the requirements for preparing a worst-case release scenario analysis and completing a five-year accident history for facilities. It details the parameters and analysis methods for offsite consequence analysis (OCA), including endpoints, wind speed, temperature, and height of release. It also specifies the requirements for worst-case release scenario analysis, including the determination of release quantity and the assumptions for the release of toxic gases. The section applies to Program 1, 2, and 3 processes.
The subpart also outlines the parameters and calculations for determining worst-case release scenarios for toxic liquids, flammable gases, and flammable liquids. It includes instructions for calculating volatilization rates, vapor cloud explosions, and distance to endpoints, as well as guidelines for using air dispersion modeling techniques and proprietary models. The owner or operator must consider passive mitigation systems and prevailing weather conditions in their calculations.
Furthermore, this set of regulations outlines the considerations and factors that must be taken into account when conducting OCAs for regulated toxic and flammable substances. It includes criteria for selecting worst-case and alternative release scenarios, defining offsite impacts on population and the environment, and reviewing and updating analyses. It also requires documentation of the scenarios and mitigation systems considered.
In addition, the subpart outlines the requirements for reporting and documenting accidental releases from covered processes, including alternative release scenarios, estimated quantity released, distance to endpoints, and potential impacts on population and environmental receptors.
It also includes the reporting requirements for the five-year accident history, detailing specific information needed for each accidental release, such as date, time, chemicals released, impacts, and any operational or process changes made as a result of the release.
Note: The hazard assessment and five-year accident history are not required in OSHA's process safety management standard, which is why they are not traditionally understood as being part of the 14 elements of PSM.
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