Conduct a Process Hazard Analysis: PSM Element 3 Checklist
Conduct a Process Hazard Analysis: PSM Element 3 Checklist
Author: Fidelis Associates | Published: 2026-03-03 | Last Updated: 2026-03-03
Meta Description: Checklist for OSHA 1910.119(e) Process Hazard Analysis — verify PHA methodology, team composition, revalidation schedule, and recommendation tracking.
OSHA Reference
Under OSHA's Process Safety Management standard 29 CFR 1910.119(e), employers must perform an initial process hazard analysis appropriate to the complexity of the process. The PHA must use one or more of the following methodologies: What-If, Checklist, What-If/Checklist, HAZOP, FMEA, Fault Tree Analysis, or an equivalent methodology. PHAs must be updated and revalidated at least every five years. The PHA team must include employees with expertise in engineering and process operations, and at least one member must be knowledgeable in the specific process being evaluated.
Fidelis Insight
PHA is the systematic identification and evaluation of potential hazards associated with a process. It is the heart of PSM — the element where hazards are identified, risk is evaluated, and safeguards are examined. A well-conducted PHA produces actionable recommendations that prevent incidents. A poorly conducted one creates a false sense of security.
The quality of a PHA depends on three factors: the accuracy of the process safety information it's built on, the competence and diversity of the team conducting it, and the rigor with which recommendations are tracked to resolution. Organizations that treat PHA as a compliance exercise — rather than a genuine hazard evaluation — consistently underperform in audits and, more critically, in preventing incidents.
Strong PHA programs go beyond the initial study. They maintain a living system where revalidations evaluate what has changed since the last review, incident findings are incorporated, and recommendations are closed with documented evidence — not just assigned and forgotten.
Common Gaps We See
- ⚠ PHAs conducted as compliance exercises rather than genuine hazard evaluations
- ⚠ Recommendations generated but not tracked to resolution
- ⚠ Revalidation simply re-approves old studies without evaluating changes since last review
- ⚠ PHA team lacks process-specific expertise or operational representation
- ⚠ PSI used as basis for PHA is outdated or incomplete
- ⚠ No linkage between PHA findings and operating procedures, training, or MI programs
- ⚠ Safeguard analysis is superficial — credit taken for safeguards that are not verified
- ⚠ Previous incident and near-miss findings not incorporated into revalidations
Best Practices Checklist
Methodology & Scope
- [ ] Initial PHA completed for every covered process
- [ ] Appropriate methodology selected (HAZOP, What-If, Checklist, FMEA, Fault Tree, or equivalent)
- [ ] PHA scope covers all operating modes: normal, startup, shutdown, temporary, and emergency
- [ ] Hazards of the process identified including toxic, fire, and explosion scenarios
- [ ] Previous incidents and near-misses reviewed as part of the analysis
Team Composition
- [ ] Team includes personnel with expertise in engineering and process operations
- [ ] At least one member knowledgeable in the specific process being evaluated
- [ ] Employee participation includes operators with field experience
- [ ] Team leader/facilitator trained in the PHA methodology
Recommendations & Follow-Through
- [ ] Recommendations are specific, actionable, and assigned to a responsible owner
- [ ] Due dates are established and tracked
- [ ] Closure requires documented evidence — not just acknowledgment
- [ ] Unresolved recommendations are escalated and risk-ranked
- [ ] Recommendations communicated to affected personnel
Revalidation
- [ ] Revalidations completed at least every 5 years
- [ ] Revalidation evaluates changes since last PHA (MOCs, incidents, new equipment)
- [ ] Updated PSI used as the basis for revalidation
- [ ] Previous PHA recommendations reviewed for completion and effectiveness
Scoring Tip
- 15–18 checks = Strong PHA program
- 9–14 checks = Needs improvement
- 0–8 checks = Immediate action required
Practical Use
Use this checklist during PHA planning, execution, and close-out. Before starting a PHA or revalidation, verify that PSI is current and complete — a PHA built on outdated information produces unreliable results. After completion, track every recommendation through resolution and verify that findings are reflected in procedures, training, and mechanical integrity programs.
Key Takeaways
- PHA quality depends on accurate PSI, competent teams, and rigorous follow-through on recommendations.
- Revalidation is not re-approval — it must evaluate what has changed since the last study.
- Recommendations without documented closure are a leading OSHA citation area.
- Incorporate incident and near-miss findings into every revalidation cycle.
- PHA findings should drive updates to operating procedures, training, and mechanical integrity programs.
Assess Your Program
Use this checklist as a starting point, then benchmark your program with a FidelisCheck PSM assessment.
Related Resources
- What is Process Safety Management? A Complete Guide
- The 14 Elements of PSM: A Practitioner's Breakdown
- OSHA 1910.119 PSM Compliance Checklist
- How to Conduct a Process Hazard Analysis (PHA)
Frequently Asked Questions
How often must a process hazard analysis be revalidated? OSHA 29 CFR 1910.119(e)(6) requires that PHAs be updated and revalidated by a team meeting the requirements of the standard at least every five years after the initial PHA is completed. Revalidation is not simply re-approving the previous study. It must evaluate all changes since the last PHA, including MOCs, incidents, near-misses, new equipment, and updated PSI. The five-year clock runs from the completion date of the most recent PHA or revalidation.
Who must be on the PHA team? Under 1910.119(e)(4), the PHA must be performed by a team with expertise in engineering and process operations, and the team must include at least one employee who has experience and knowledge specific to the process being evaluated. OSHA also requires that one member be knowledgeable in the PHA methodology being used. Best practice is to include an experienced operator, a process engineer, a maintenance representative, and an independent facilitator trained in the selected methodology.
What PHA methodologies does OSHA accept? OSHA 29 CFR 1910.119(e)(2) lists six acceptable methodologies: What-If, Checklist, What-If/Checklist, Hazard and Operability Study (HAZOP), Failure Mode and Effects Analysis (FMEA), and Fault Tree Analysis. The standard also permits "an appropriate equivalent methodology." The selection should be appropriate to the complexity of the process. HAZOP is the most widely used for complex continuous processes, while What-If/Checklist is common for simpler or batch operations. OSHA does not mandate one methodology over another, but the employer must be able to demonstrate that the chosen approach is adequate for the process.
Fidelis Associates provides PSM compliance consulting and assessment services through FidelisCore and FidelisGap. Our team brings 40+ years of combined experience across major operators including Chevron, Valero, and Shell.
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