Since 2013, our consultants have been working with a terminal storage and distribution company in Houston on numerous Environmental, Health and Safety (EHS) projects. The terminal provides storage and distribution services for chemicals, clean petroleum products, gas, vegetable oils, biofuels, and oleochemicals.
In early 2020, Braun Intertec had the opportunity to assist the client in the revalidation of their existing Process Hazard Analysis (PHA). The client has several processes which are covered by the Occupation Safety and Health Administration (OSHA) PSM standard and the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP). Per the OSHA PSM and EPA RMP programrequirements, PHAs must be updated and revalidated every five years. The five-year anniversary for the client’s PHA just so happened to come in tandem with the unexpected global COVID-19 pandemic.
The project was scheduled to begin during the first quarter of 2020; however, as was experienced by many industries and businesses, the COVID-19 pandemic caused work and travel restrictions, as well as project delays. Braun Intertec worked with the client to coordinate logistics for the PHA Team to perform the PHA revalidation activities in a safe manner once Texas businesses and services began to reopen.
Braun Intertec used the Hazard and Operability (HAZOP) hazard evaluation and What-If Checklistmethodologiesto conduct the PHA revalidation studies. Braun Intertec, and the rest of the PHA Team, performed the PHA revalidation activities and helped identify potential hazards, areas for improvement, and solutions to potential high-risk scenarios and situations at their facility. At the end of the revalidation, Braun Intertec provided the client with a report on the findings, a summary of recommendations, and a way to track PHA recommendations to closure.
All of this was completed in consideration of each entity’s desire to follow the Center for Disease Control and Prevention (CDC) protocols, keep their employees healthy, and prevent the spread of COVID-19. The PHA Team took precautions to perform the PHA including in-person utilization of masks and social distancing, as well as performing many of the PHA revalidation activities utilizing video conferencing. While this methodology presented some drawbacks like lack of quick access to areas of concern, the occasional “I’m sorry…no, you first” interjections, and the need for multiple sessions over more efficient in-person sessions, both parties were able to quickly adapt and bring the project to completion.
Braun Intertec consultants are proud of their contributions and assistance to our client in maintaining compliance and prioritizing health and safety for all involved during a pandemic.
