Introduction | Process Hazard Analysis Revalidation April 2025 — by Carolyn Bott, Process Safety Group Manager — In the world of industrial operations, hazards are a given — but unmanaged hazards are a risk no facility can afford. A well-executed Process Hazard Analysis (PHA) is a vital safeguard, helping teams identify potential risks and define the controls needed to mitigate them. But a PHA isn’t a one-time event. As facilities and operations evolve, so must the analysis. That’s where a PHA Revalidation comes in. What is a PHA Revalidation? A PHA revalidation is a systematic update of an existing PHA study to ensure that it accurately reflects current operations, risks, and safeguards. Mandated under OSHA’s Process Safety Management (PSM) standard  (29 CFR 1910.119), PHA revalidations are required at least once every five years. This ensures that facilities consistently assess whether existing safeguards and Independent Protection Layers  (IPLs) are still appropriate and effective. Unlike a first-time PHA, a revalidation starts with reviewing the previous study. The team evaluates modifications — be it process design, control systems, staffing, procedures, or incident history — and determines whether those changes introduce new risks or warrant updates to the previous Process Hazard Analysis study. It should be noted that in some cases, a facility may determine that the existing PHA is no longer a reliable baseline — perhaps because of major modifications, process redesign, or poor quality in the original study. In these situations, a full PHA redo may be the better option. Methodologies Commonly Used in PHA Revalidations Several risk assessment methodologies are used during PHA revalidations, depending on process complexity and organizational preference. These include: HAZOP (Hazard and Operability Study) : A systematic, guideword-based approach for continuous and batch processes LOPA (Layers of Protection Analysis) : A method for evaluating the effectiveness of protection layers in reducing the frequency or consequence severity of hazardous events What-If and Checklist Analyses : Useful for simpler systems or as supplementary tools HAZID (Hazard Identification Study) : Often applied in the early design phase or as a high-level review FMEA (Failure Modes and Effects Analysis) : Focuses on component-level failure scenarios Bowtie Analysis : Visual mapping of causal pathways and safeguards for major hazards These methodologies are not mutually exclusive — they are often used in combination. The chosen methodology(s) should match the process and risk profile. Regulatory Requirements and OSHA Expectations for PHA Revalidations According to OSHA, a PHA must be revalidated at least every five years to ensure it remains consistent with the current process. The revalidation must be conducted by a team with expertise in engineering, operations, and hazard analysis methodology. The team should evaluate changes in equipment, procedures, and materials; verify that recommendations from previous PHAs have been resolved; and confirm that documentation and drawings (such as P&IDs) are current. OSHA further clarifies that a PHA revalidation doesn’t need to start from scratch. It can build upon the previous PHA, provided the review is thorough and documented. Failing to properly revalidate — whether by missing the five-year deadline or conducting an insufficient review — can lead to citations and increased risk exposure. Should I Revalidate Sooner Than Five Years? While the five-year cycle is the regulatory minimum, some facilities choose or need to revalidate more frequently. Situations that may warrant earlier review include: -          Significant process changes such as new equipment, revised control strategies, or major throughput adjustments -          Facility expansions or new unit operations -          Introduction of new chemicals or process conditions -          Recurring incidents or near misses suggesting underlying hazards were missed -          Internal audits that identify PHA gaps or non-compliance -          Evolving industry standards or new safety guidance that impact existing risk assessments In such cases, updating the PHA before the five-year mark can strengthen safety performance and demonstrate due diligence to regulators and insurers. Five Common Challenges in PHA Revalidations Executing a quality PHA revalidation takes planning, expertise, and cross-functional engagement. Below, we describe five common challenges that facilities face when conducting a Process Hazard Analysis Revalidation. 1.      Inadequate Documentation and Information Management  A revalidation is only as good as the information available. If the previous PHA scenarios were poorly documented or if process safety information (P&IDs, chemistries, etc.) hasn’t been kept current, the team will struggle. Without complete, up-to-date data on what has changed since the last PHA, important scenarios might be overlooked, or the team may waste time reconfirming basic facts. 2.     Loss of Key Knowledge and Stakeholder Engagement It isn’t uncommon to find that the team who performed the initial PHA has transferred, retired, or simply moved into new roles by the time of revalidation. If a PHA Reval is not documented effectively, nor involves the appropriate process experts, understanding of the process risks can be lost. This type of insufficient stakeholder engagement can result in missing insights into how the process truly operates or deviates. Every PHA relies on the collective knowledge of its team and if that’s weakened, the revalidation may miss hazards or misunderstand the adequacy of IPLs. 3.     Poor or Inconsistent Methodology Application If your PHA revalidation isn’t executed with consistent and up-to-date methods, gaps can occur. In some cases, the prior PHA might have used a different method or risk criteria than what the company uses now, causing confusion. For example, if the initial PHA methodology was misapplied or too simplistic for the process, it can result in the need for substantial correction down the road. Ensuring a comprehensive and systematic approach is applied during revalidation is vital to avoid leaving gaps. 4.     Underestimating Time and Resources Required PHA revalidations can be resource intensive. A common mistake is assuming a revalidation will be quick since “ we’ve done this before ”, and then not allocating enough time or personnel knowledgeable in the process. The result can be rushed sessions, incomplete reviews, or missing documentation. If an organization doesn’t budget adequate time (including for pre-work and team meetings), the five-year deadline can sneak up. 5.     Failure to Close Gaps from Previous PHA Recommendations A situation that many face during a PHA revalidation is discovering that some recommendations or gaps  from the last PHA were never implemented or fully resolved. Not only does this pose an ongoing risk, but it also complicates the analysis — the team might find themselves re-discussing hazards that should have been mitigated. OSHA expects that existing PHA recommendations are tracked and completed before revalidation ​. If that hasn’t happened, your facility faces both compliance issues and potentially repetitive findings. This issue often stems from lack of a robust management system for PHA action items. Anticipating and addressing these challenges early can significantly improve the quality of your PHA revalidation process. Best Practices for an Effective PHA Revalidation To mitigate the challenges described above, facilities should adopt several best practices for PHA revalidations: Prepare thoroughly : Update your process safety information, drawings, procedures, and incident history before the first team meeting. Performing this type of “ mini   audit ” of changes and process safety performance since the last PHA will help drive the revalidation scope. Engage experienced facilitators : Facilitators with expertise in the methodology selected for the reval can guide the process and ensure consistency across nodes and scenarios. Ultimately, your PHA Reval team should consist of experienced operations personnel, engineers familiar with the process, and a competent facilitator. Additionally, involving members from the original PHA team and/or certified PHA leaders can benefit the effort. Involve stakeholders:  Cross-functional support from those in operations, engineering, maintenance, and even management stakeholders who understand the process will increase your ability to maintain consistency and accuracy throughout the revalidation process. Verify implementation of past recommendations:  A revalidation is an opportunity to check the status of all previously identified hazards. Best practice is to explicitly review how each risk scenario identified last time has been addressed. The team should verify that no known hazard has been forgotten. If some recommendations were deferred or not resolved, this is the time to reassess those risks and decide on an action. Additionally, incorporate any relevant incident learnings (from your site or industry) to enhance the prior analysis​. By looping back on past findings and new learnings, the revalidation closes gaps and solidifies your facility’s risk baseline. Document and track everything : Just as you review old recommendations, establish a strong process for following through on new PHA recommendations coming out of the revalidation. This includes clearly prioritizing them (e.g. using a risk matrix or LOPA results to rank urgency), assigning responsibility, and setting deadlines. Remember, OSHA requires documented resolution of PHA recommendations​ — having a tracking system not only aids safety but keeps your facility compliant. Consider partnering with a qualified PHA facilitator : One of the best investments for a successful PHA revalidation can be partnering with a skilled facilitator. An experienced, third-party PHA facilitator can provide a litany of benefits — including chemical and process knowledge across industries. Beyond providing expert guidance, facilitators can also serve as an objective, unbiased perspective. When considering an external PHA facilitator, look for a provider who goes beyond “ checking the boxes. ” Facilitators should also offer effective prioritization of risks and recommendations. Additionally, a facilitator should be able to present an actionable gap closure game plan that includes recommendations for trusted engineering solutions providers  who can support resolving identified issues.     You’ve Completed Your PHA Reval — What Next? A successful PHA revalidation doesn’t end when the last worksheet is signed. The real value comes from implementing recommendations and closing identified gaps. At this stage, facilities should: -          Prioritize recommendations  using risk matrices or LOPA to focus efforts on high-consequence scenarios -          Develop actionable plans  for implementation, assigning ownership, and tracking progress -          Work with a facilitator or engineering partner  who can help close common recommendations such as SIS upgrades, BPCS changes, Alarm Management improvements, BMS modifications, Facility Siting enhancements, and Fire & Gas system updates. -          Document closure , including verification of effectiveness and updates to procedures or training as needed Without follow-through, a PHA revalidation becomes a compliance checkbox rather than a meaningful tool for reducing risk. The Takeaway | Turn Your PHA Reval Findings into Forward Motion Process safety isn’t static — and your PHA shouldn’t be either. Regular, well-executed PHA revalidations are essential to staying compliant with OSHA, maintaining operational continuity, and safeguarding personnel and assets. For facilities navigating complex changes, aging infrastructure, or resource constraints, engaging with experienced PHA facilitators  can bring structure, insight, and measurable outcomes to the revalidation process. When done right, PHA revalidations don’t just ensure compliance — they create a roadmap for safer, smarter operations.

Greenville, SC – April 2025 – aeSolutions, a provider of integrated, end-to-end critical system solutions that empower resilient operations and safer communities, is proud to announce three strategic internal promotions, reflecting the company’s continued commitment to realizing employee potential through the achievement of client success. Roland Stock, PMP, a current member of our Senior Leadership Team, has been named Vice President of Projects , where he will lead our Project Management Office and cross-functional project teams in the development and execution of projects to achieve our clients’ goals. Roland brings deep experience in project leadership and a strong track record of delivering complex solutions across industries.  Chris Powell, PE, CFSE, joins our Senior Leadership as the Director of Engineering where he will focus our Engineering Team’s development, collaboration and performance to drive our mission of improving industry by guiding our clients to increasingly resilient operations and safer communities. Chris will apply his leadership and expertise developed through the application of the Safety Lifecycle in his previous roles, including his most recent position as the Functional Safety Group Manager. Emily Henry, PE, CFSE, has been appointed Functional Safety Group Manager , where she will lead the team of safety professionals responsible for delivering lifecycle safety services. Her depth of expertise in functional safety as well as her relentless drive for our client’s desired outcomes position her to lead this group. “ These promotions reflect the depth and breadth of talent and the strategic importance of developing our leaders’ potential, ” said Chris Neff, COO at aeSolutions. “ Roland, Chris, and Emily have each demonstrated dedication to our clients’ success through exceptional leadership, technical acumen, and progressive experience. We are thrilled to see them step into these new roles. ” Visit aeSolutions for more information.

Introduction | Control System Migrations | Part 6 April 2025 — by Tom McGreevy, PE, PMP, CFSE — By now, you've successfully navigated the Front-End Loading (FEL) phases , clearly defined your scope, budget, and schedule , and received approval for funding. However, the real challenge arises when plans meet the unpredictability of real-world execution. Monitoring, managing changes, and reporting effectively during this execution phase are critical to a project’s success. Contractor Reporting Requirements Detailed reporting expectations must be clearly defined early — ideally during the solicitation phase  — to ensure effective project control. Three key elements to consider with contractor reporting requirements are: Required Information Must be Specified Explicitly state the type of information needed, including task progress, upcoming activities, recent accomplishments, roadblocks, and actionable items. Specify the report format ( e.g., Excel, Microsoft Project, Primavera ) to ensure data usability. Reporting Frequency Reporting intervals — which are typically established based on the project’s size — enable timely identification of issues and corrective action. Frequent communication helps maintain project momentum and clarity. Report Detail Reports should provide enough detail to enable actionable decisions without overwhelming the management team. They should also include specific metrics on schedule performance, budget status, and risk assessment outcomes. Managing Change Orders Changes will happen. Whether driven by unexpected conditions, improved technical ideas, or shifting requirements, a structured change management process with proper documentation is essential. Change orders fall into two types of categories, which is determined by the reasoning behind the change: Design Change Orders Design changes can be positively received as they often involve beneficial, innovative ways to achieve the same project goals more efficiently. Design changes usually involve adjustments in how requirements are implemented rather than what is implemented. They typically deliver cost, schedule, or reliability benefits. Scope Change Orders Usually driven by unforeseen events or missed requirements, scope changes can be particularly challenging to justify. They require a thorough evaluation and management buy-in of documented impact on costs, schedule, and potential new risks. Even legitimate scope changes can face high scrutiny, as they must demonstrate independent financial justification and alignment with organizational priorities. Both types of change orders should follow a structured approach: Document the proposed change via a Request for Information (RFI) Group review to determine if there is a compelling reason supporting the change Estimate the impact on scope, schedule, cost, & new risks Approval or rejection by the designated management team This ensures transparency and control, preventing unauthorized or detrimental changes.   Earned Value Management  Earned Value Management (EVM) is a powerful tool that integrates project scope, schedule, and budget. To leverage EVM effectively, projects must be set up correctly during FEL phases with: 1.      A well-defined Work Breakdown Structure (WBS) 2.      Resource-loaded schedules 3.      Documented cost allocations Image Source EVM allows project managers to detect early deviations in schedule or budget, enabling timely corrective actions. The primary metrics used in EVM include: Planned Value (PV):   What you planned to spend. This can also be referred to as Budgeted Cost of Work Scheduled (BCWS). Earned Value (EV):   The amount of work that’s been performed and the budgeted cost of that work. Actual Cost (AC):   The actual  expenditure for the work completed, sometimes referred to as Actual Cost of Work Performed (ACWP). Regularly tracking these metrics helps maintain control and transparency, providing valuable insight into how well a team is managing budget and schedule, in addition to indicating early warnings that can help prevent minor deviations from escalating. The Takeaway Effective project monitoring, proactive change management, and thorough reporting are keys to successful control system migrations. When executed properly, these processes provide significant stress relief, enabling project teams to maintain control amidst inevitable uncertainties. Organizations benefit immensely from clearly defined reporting standards, structured change processes, and earned value management practices. By incorporating these practices early and consistently, teams enhance project outcomes and organizational confidence in project delivery. In the meantime, check out parts 1-5 of our control systems migration blog series .

A process control loop is a system of sensors, controllers, and actuators that work together to maintain a process variable, such as temperature or pressure, at a desired setpoint. Control loops are fundamental to automated process control in industrial settings. Acronyms & Terms Glossary <- More Definitions Process Control Loop A process control loop is a system of sensors, controllers, and actuators that work together to maintain a process variable, such as temperature or pressure, at a desired setpoint. Control loops are fundamental to automated process control in industrial settings. Our Services aeSolutions Announces Key Leadership Promotions to Support Continued Client Success aeSolutions announces leadership promotions to drive client success and strengthen resilient, safer operations across industries. Control System Migrations | Part 6 | Monitoring, Change Management, & Reporting Monitoring, managing, and reporting during execution is where control system migration plans meet real-world performance. Case Study: Achieving a High-Risk Systems Overhaul on an Accelerated Schedule aeSolutions, a Siemens Solution Partner, delivered a critical CUP control system overhaul for TGES America on an accelerated schedule.

ANSI/ISA-16511 (IEC 61511) is an industry standard for best practices related to safety instrumented systems (SIS), Covering over the activities involved in the design, operation and maintenance of instrumented systems, from sensor through final element, used to achieve functional safety in the process industries. Note: ISA 84 was a previous edition of the standard. Acronyms & Terms Glossary <- More Definitions ANSI ISA-16511 (IEC 61511) ANSI/ISA-16511 (IEC 61511) is an industry standard for best practices related to safety instrumented systems (SIS), Covering over the activities involved in the design, operation and maintenance of instrumented systems, from sensor through final element, used to achieve functional safety in the process industries. Note: ISA 84 was a previous edition of the standard. Our Services aeSolutions Announces Key Leadership Promotions to Support Continued Client Success aeSolutions announces leadership promotions to drive client success and strengthen resilient, safer operations across industries. Control System Migrations | Part 6 | Monitoring, Change Management, & Reporting Monitoring, managing, and reporting during execution is where control system migration plans meet real-world performance. Case Study: Achieving a High-Risk Systems Overhaul on an Accelerated Schedule aeSolutions, a Siemens Solution Partner, delivered a critical CUP control system overhaul for TGES America on an accelerated schedule.

NFPA 85 is the standard from the National Fire Protection Association that outlines operating safety and how to prevent explosions and implosions in boilers with greater than 12.5 MMBTUH, pulverized fuel systems, and heat recovery steam generators. This code also addresses the minimum guidelines for the installation, operation, and maintenance of this equipment. Acronyms & Terms Glossary <- More Definitions NFPA 85 NFPA 85 is the standard from the National Fire Protection Association that outlines operating safety and how to prevent explosions and implosions in boilers with greater than 12.5 MMBTUH, pulverized fuel systems, and heat recovery steam generators. This code also addresses the minimum guidelines for the installation, operation, and maintenance of this equipment. Our Services aeSolutions Announces Key Leadership Promotions to Support Continued Client Success aeSolutions announces leadership promotions to drive client success and strengthen resilient, safer operations across industries. Control System Migrations | Part 6 | Monitoring, Change Management, & Reporting Monitoring, managing, and reporting during execution is where control system migration plans meet real-world performance. Case Study: Achieving a High-Risk Systems Overhaul on an Accelerated Schedule aeSolutions, a Siemens Solution Partner, delivered a critical CUP control system overhaul for TGES America on an accelerated schedule.