OSHA Compliance & Support | Safety Inspections – Safety Audits | Cost-Effective Safety Consulting

Process Hazard Analysis (PHA) Services in Houston, TX

Aggie Safety provides Process Hazard Analysis, LOPA, What-If studies, Root Cause Analysis, Facility Siting, and consequence modeling using PHAST software for industrial facilities across Greater Houston.

Process Hazard Analysis

These studies are led by Sumit Anand, PE, CTO at Aggie Safety, with more than 20 years of experience in process safety, oil and gas, petrochemicals, and gas processing including direct experience conducting and facilitating PHAs at refineries, chemical plants, and gas processing facilities.

A PHA is not a paperwork exercise. Done correctly, it identifies the specific scenarios that could injure workers, damage equipment, or cause an off-site release -- and it documents the layers of protection that stand between a hazard and a catastrophic outcome. For facilities covered under OSHA PSM (29 CFR 1910.119) or EPA RMP (40 CFR Part 68), PHA is a mandatory program element with a revalidation requirement every five years. For facilities not yet under PSM, a PHA is still the most effective way to understand what your process can do to you before it does it. Could you be paying less? Investors Choice Mortgages reviews your current loan and finds refinancing options that save you money.
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Key Takeaways

  • PHA is a required PSM/RMP element (29 CFR 1910.119(e), 40 CFR 68.67) and must be revalidated every five years.

  • Methodology selection matters: HAZOP, What-If, FMEA, and Checklist each serve different process types and risk profiles. Aggie Safety selects and facilitates the right one for your facility.

  • LOPA (Layer of Protection Analysis) quantifies risk reduction from independent protection layers — bridging the gap between a qualitative HAZOP and a full quantitative risk assessment.

  • Facility Siting studies evaluate whether occupied buildings near process hazards are adequately protected from blast, fire, and toxic release scenarios.

  • PHAST (DNV consequence modeling software) allows Aggie Safety to model toxic, flammable, and explosion consequences quantitatively — supporting RMP off-site consequence analysis, facility siting, and emergency planning.

  • Root Cause Analysis (RCA) applied after incidents or near-misses prevents recurrence by identifying systemic failures, not just the triggering event.

Services Overview

Process Hazard Analysis Services We Provide

Aggie Safety delivers the full spectrum of PHA and process risk services. Each study is scoped to the specific methodology, process type, and regulatory context your facility requires. Below is what each service covers and when it applies.

1. Process Hazard Analysis (PHA) — HAZOP

A Hazard and Operability Study (HAZOP) is the most rigorous and widely used PHA methodology for continuous process systems — pipelines, reactors, distillation columns, heat exchangers, and similar equipment. It uses a structured set of guidewords (No, More, Less, Reverse, Other Than, As Well As, Part Of) applied systematically to each node of the process to generate deviation scenarios.

Aggie Safety facilitates HAZOPs using up-to-date P&IDs, operating procedures, and process safety information. Our team brings working process knowledge to the table — not just facilitation mechanics. For a HAZOP to produce actionable findings, the facilitator needs to understand the chemistry and thermodynamics well enough to recognize which deviations are credible and which consequences are realistic. That is what 20-plus years of process engineering experience provides.

HAZOP outputs include: identified hazards and consequences, existing safeguards, identified gaps, and recommendations with assigned owners and due dates — formatted to satisfy PSM/RMP documentation requirements and internal insurance audits.

Applicable standards: OSHA 29 CFR 1910.119(e), 40 CFR 68.67 (RMP), IEC 61882 (HAZOP standard), API RP 14C (for offshore/onshore gas facilities).

2. What-If Analysis

What-If analysis is a structured brainstorming method that asks "What if this specific deviation or failure occurred?" across defined areas of a process. It is less rigorous than a full HAZOP but faster and well-suited for batch processes, simpler operations, facilities with limited P&ID documentation, or initial-phase hazard screening before detailed engineering is complete.

Aggie Safety conducts What-If studies as standalone engagements or as part of a combined PHA approach where some process sections warrant HAZOP depth and others are adequately addressed with What-If. We document all scenarios, consequences, existing safeguards, and recommendations in a format that meets PSM/RMP requirements.

What-If is also commonly used for Management of Change (MOC) reviews when a process modification is too significant for a simple checklist but does not justify a full node-by-node HAZOP.

3. Layer of Protection Analysis (LOPA)

LOPA is a semi-quantitative risk assessment technique applied to high-consequence scenarios identified during a HAZOP or What-If study. Where a HAZOP identifies that a scenario is hazardous and that safeguards exist, LOPA answers the question: are those safeguards sufficient?

The method assigns initiating event frequencies and calculates Independent Protection Layer (IPL) credit for each safeguard -- considering demand rate, probability of failure on demand (PFD), and conditional modifiers -- to determine the mitigated event frequency. That frequency is then compared against a target risk tolerance (typically expressed as a maximum tolerable frequency for fatality scenarios, process demands, or environmental releases).

LOPA results directly drive Safety Instrumented System (SIS) requirements. When LOPA shows that existing layers are insufficient, the gap is typically addressed through a Safety Instrumented Function (SIF) designed to IEC 61511 / ISA 84.00.01, with a specified Safety Integrity Level (SIL). Aggie Safety can scope and support SIL determination as part of the LOPA engagement.

Applicable standards: IEC 61511 / ISA 84.00.01 (SIS), CCPS Layer of Protection Analysis: Simplified Process Risk Assessment, OSHA 29 CFR 1910.119.

4. Root Cause Analysis (RCA)

Root Cause Analysis is the systematic investigation of an incident, near-miss, or repeated equipment failure to identify the underlying systemic causes -- not just the immediate trigger. OSHA PSM requires incident investigation within 48 hours of an event and documentation of root causes, corrective actions, and communication to affected personnel (29 CFR 1910.119(m)).

Most process incidents are not caused by a single failure. They result from the combination of a physical failure, a procedural gap, and an organizational factor that allowed the failure mode to go undetected or uncorrected. RCA methods used by Aggie Safety include:

  • Fault Tree Analysis (FTA): deductive logic tree mapping from an undesired top event backward to basic failure causes.
  • Bow-Tie Analysis: visual representation linking threat pathways through a top event to consequences, with barriers mapped on both sides.
  • 5-Why Analysis: iterative causal chain interrogation suited to simpler incidents or as an initial screening tool.
  • Barrier Analysis: evaluation of which preventive and mitigating barriers failed or were absent.

RCA deliverables include: timeline of events, identified root and contributing causes, corrective and preventive actions (CAPAs) with owners and due dates, and a lessons-learned summary for communication to affected employees -- formatted to satisfy PSM incident investigation requirements.

5. Facility Siting Study

A Facility Siting Study evaluates whether occupied structures -- control rooms, administrative buildings, maintenance shops, break rooms -- are located at safe distances from process equipment that could release hazardous energy in an accident scenario. It is a required component of Process Safety Information under PSM (29 CFR 1910.119(d)) and is typically triggered or updated by a PHA, a significant process expansion, or an MOC involving new building construction or occupancy changes.

The primary hazard scenarios evaluated in a facility siting study are:

  • Vapor cloud explosion (VCE) overpressure -- blast loading on building structures and occupants
  • Pool fire and jet fire thermal radiation -- heat flux at occupied locations
  • Flash fire -- flammable vapor cloud ignition without significant overpressure
  • Toxic gas release -- concentration at occupied buildings under credible release and atmospheric conditions

Aggie Safety conducts facility siting studies using consequence modeling (PHAST, described below) to quantify hazard distances and compares results against accepted risk criteria from API RP 752 (Management of Hazards Associated with Location of Process Plant Permanent Buildings) and API RP 753 (Management of Hazards Associated with Location of Process Plant Portable Buildings).

Where a building is identified as inadequately sited, Aggie Safety provides risk reduction options: relocation, blast-rated construction upgrades, occupancy reduction, or administrative controls to limit personnel exposure during high-hazard operations.

6. Consequence Modeling with PHAST Software

PHAST (Process Hazard Analysis Software Tool) is DNV's industry-standard consequence modeling software, used by major oil companies, chemical manufacturers, and regulators worldwide. Aggie Safety uses PHAST to model the physical consequences of accidental releases of hazardous substances -- providing the quantitative foundation for facility siting decisions, RMP off-site consequence analysis, emergency response planning, and LOPA scenario frequency calibration.

PHAST modeling capabilities used by Aggie Safety include:

  • Toxic gas dispersion: concentration vs. distance plots for toxic releases under representative atmospheric stability conditions (Pasquill-Gifford stability classes); comparison against IDLH, ERPG, and AEGL values.
  • Flammable gas dispersion: Lower Flammable Limit (LFL) and 50% LFL distances for vapor cloud formation from liquid or gas releases.
  • Vapor cloud explosion (VCE) overpressure: consequence distances for 1 psi, 3 psi, and 8 psi overpressure isopleths using Multi-Energy or Baker-Strehlow-Tang (BST) methods.
  • Pool fire and jet fire thermal radiation: heat flux (kW/m2) vs. distance for liquid pool fires and pressurized jet fires.
  • Flash fire extent: vapor cloud footprint for flammable releases below auto-ignition temperature.
  • BLEVE fireball: thermal radiation modeling for catastrophic failure of pressurized liquid containers.

PHAST output directly supports EPA RMP worst-case and alternative release scenario analysis under 40 CFR Part 68, Subpart B. Aggie Safety uses PHAST in conjunction with site-specific meteorological data, release inventory data, and realistic failure scenarios to produce defensible, code-compliant consequence analysis reports.

METHODOLOGY COMPARISON

Choosing the Right PHA Methodology

The table below summarizes when each methodology applies, what it produces, and what regulatory requirement it addresses. Many facilities use a combination for example, HAZOP for the main process with LOPA applied to the highest-consequence scenarios identified.
Methodology Best Suited For Key Output Regulatory Basis
HAZOP Continuous processes with defined P&IDs: refineries, chemical plants, gas processing units Deviation scenarios, consequences, safeguards, and recommendations for each process node OSHA 29 CFR 1910.119(e); 40 CFR 68.67; IEC 61882
What-If Batch processes, simpler operations, MOC reviews, early-phase hazard screening Scenario list with consequences, safeguards, and recommendations OSHA 29 CFR 1910.119(e); 40 CFR 68.67
LOPA High-consequence scenarios identified in HAZOP/What-If needing quantified IPL adequacy assessment Mitigated event frequency vs. target; SIL requirements for safety instrumented functions IEC 61511 / ISA 84.00.01; CCPS LOPA guidelines
Root Cause Analysis Post-incident or near-miss investigation; repeat equipment failures Root and contributing causes; corrective/preventive actions; lessons-learned report OSHA 29 CFR 1910.119(m); 40 CFR 68.81
Facility Siting Process expansions, new occupied building placement, PSI documentation, MOC involving occupancy Hazard distances; building risk assessment; risk reduction recommendations API RP 752 / 753; OSHA 29 CFR 1910.119(d)
PHAST Consequence Modeling RMP off-site consequence analysis, facility siting, emergency planning, LOPA scenario calibration Toxic dispersion, flammable/explosion/fire consequence distances; RMP-compliant analysis report 40 CFR Part 68 Subpart B (RMP); API RP 752
Our Process

How Aggie Safety's Engineering Support Works

Step 1
Free Scoping Call

We review your facility type, process descriptions, existing PSM/RMP status, and what triggered the study need — initial PHA, five-year revalidation, MOC, post-incident, or new construction. We confirm the appropriate methodology and estimate study scope.

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Step 2
Pre-Study Preparation

Aggie Safety reviews your Process Safety Information package: P&IDs, PFDs, cause-and-effect diagrams, equipment datasheets, operating procedures, prior PHA reports, and incident history. We identify gaps in documentation before the study begins — documentation gaps during a PHA session waste expensive facilitated time.

Step 3
PHA Study Sessions

We facilitate structured sessions with your operations, engineering, and maintenance teams. Aggie Safety leads the methodology while your team provides the facility-specific knowledge. Sessions are conducted on-site or remotely depending on scope and preference.

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Step 4
Documentation and Draft Report

All scenarios, consequences, safeguards, and recommendations are documented in real time. You receive a draft report for review — including a recommendation register with suggested action owners and suggested target completion dates.

Step 5
Final Report and Recommendation Tracking

Final PHA report is issued following your review comments. Aggie Safety can support ongoing recommendation closure tracking and can assist with PSM documentation updates (P&ID markups, procedure revisions, MOC documentation) arising from the study.

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Why Aggie Safety

Why Houston Facilities Choose Aggie Safety for PHA and Process Risk Studies

Facilitators with Real Process Experience

Sumit Anand, PE, brings 20-plus years of direct oil and gas, petrochemical, and gas processing experience to every PHA facilitation. He holds a master's degree in chemical engineering with a research focus in process safety and spent his career at companies including CITGO, KBR, and BASF before founding Aggie Safety's process safety practice. PHA facilitation is only as good as the facilitator's ability to recognize credible scenarios. That comes from having designed, troubleshot, and operated the kinds of systems being analyzed not from running software or reading guideword lists.

Integrated safety and Compliance

PHA findings do not exist in isolation. They connect to PSM program elements: mechanical integrity, operating procedures, MOC, training, and emergency response. Aggie Safety's team holds the full PSM/RMP picture, so recommendations from a PHA are integrated into your compliance program rather than handed off as a disconnected list.

PHAST Software Capability

Many Houston PHA consultants can facilitate a HAZOP. Very few can also run PHAST consequence models and integrate those results into the hazard analysis. Aggie Safety does both, which means facility siting evaluations and RMP consequence analyses are conducted by the same team that understands your process, not outsourced to a separate modeling group.

Scoped to Your Situation

A five-year HAZOP revalidation for a small specialty chemical facility looks very different from an initial PHA for a new gas processing unit. We scope every engagement to what your facility actually needs, not a standard package that may be more or less than what the project requires.

Regional Availability

On-site PHA facilitation is available throughout Greater Houston, including Baytown, Pasadena, Deer Park, Texas City, Freeport, and the broader Gulf Coast industrial corridor. For full team credentials, visit our About Us page.

Following Clients

Engineering work we have done in last few years

Lotte Chemical
Solvchem
Eastman
Gas Innovations
Lotte Chemical
Solvchem
Eastman
Gas Innovations

Frequently Asked questions

Answers to the most common questions about OSHA compliance, safety training, and working with Aggie Safety.
What is a Process Hazard Analysis (PHA) and when is it required?
A PHA is a systematic evaluation of the hazards associated with a covered process -- identifying scenarios that could cause injury, property damage, or environmental harm, and assessing whether safeguards are adequate. OSHA PSM (29 CFR 1910.119) and EPA RMP (40 CFR Part 68) require a PHA for facilities handling threshold quantities of highly hazardous chemicals. PHAs must be completed within specified timeframes after PSM applicability is triggered and revalidated every five years thereafter.
What is the difference between HAZOP and What-If analysis?
HAZOP (Hazard and Operability Study) is a structured, node-by-node deviation analysis using defined guidewords applied to process parameters. It is the most thorough and widely accepted PHA methodology for continuous processes and is required by many insurance carriers and corporate standards. What-If is a structured brainstorming method -- faster and less rigorous, suited for batch processes, simpler systems, or MOC reviews. Both satisfy PSM requirements when properly documented. Aggie Safety selects the methodology that fits your process type and study objectives.
What is LOPA and when does a facility need it?
LOPA (Layer of Protection Analysis) is applied after a HAZOP or What-If to quantify whether existing safeguards provide adequate risk reduction for high-consequence scenarios. It is typically triggered when a HAZOP identifies scenarios with potentially severe consequences where the team cannot confirm -- through engineering judgment alone -- that existing safeguards are sufficient. LOPA results are used to determine Safety Instrumented Function (SIF) requirements and SIL (Safety Integrity Level) targets under IEC 61511 / ISA 84.00.01.
How often does a PHA need to be revalidated?
OSHA PSM and EPA RMP both require PHA revalidation every five years (29 CFR 1910.119(e)(6), 40 CFR 68.67(f)). Revalidation confirms that all prior recommendations have been resolved or formally deferred, that the PHA reflects current process conditions, and that no significant process changes since the last PHA require additional hazard evaluation. MOCs may trigger interim PHA updates between the five-year cycle if changes are significant enough.
What is PHAST and what does consequence modeling provide?
PHAST (Process Hazard Analysis Software Tool) is DNV's industry-standard consequence modeling software. It calculates the physical effects of accidental releases: toxic gas concentrations downwind, flammable vapor cloud dimensions, explosion overpressure contours, fire thermal radiation heat flux, and BLEVE fireball extents. These results are used for RMP off-site consequence analysis, facility siting decisions, emergency planning zone determination, and to calibrate realistic consequence severity estimates in LOPA.
What is a Facility Siting Study and when is one required?
A Facility Siting Study evaluates whether occupied buildings near hazardous process areas are adequately protected against blast, fire, and toxic release scenarios. It is required as part of Process Safety Information under PSM and is typically updated after any significant process expansion, MOC affecting occupied building locations, or when a new building is proposed near a covered process. API RP 752 and 753 provide the accepted risk criteria and study methodology.
What does Root Cause Analysis deliver under OSHA PSM?
Under 29 CFR 1910.119(m), PSM requires that incidents and near-misses be investigated within 48 hours, that root causes be identified, that corrective actions be assigned and tracked, and that findings be communicated to affected personnel. An RCA conducted by Aggie Safety produces a documented investigation report that satisfies all of these requirements, with root cause and contributing cause identification, a corrective/preventive action register, and a lessons-learned summary suitable for employee communication and PSM audit demonstration.
Can Aggie Safety conduct a PHA for a facility that is not PSM-covered?
Yes. Many facilities voluntarily conduct PHAs or What-If studies because they handle hazardous materials in quantities below PSM thresholds, or because insurance requirements, corporate standards, or good engineering practice call for it. A PHA is the most effective tool for understanding process risk before an incident occurs. Aggie Safety scopes these engagements to the facility's specific risk profile and documentation needs, without the overhead of a full PSM program build.
PHA Consultation

Request a PHA Consultation for Your Houston Facility

Whether you need an initial PHA, a five-year revalidation, a LOPA to resolve a high-consequence scenario, or PHAST modeling for an RMP submittal, Aggie Safety can scope and deliver the study. Call (713) 613-2830 or fill out the form below and we will follow up promptly.
We serve industrial, chemical, and gas processing facilities throughout Greater Houston, including Baytown, Pasadena, Deer Park, Texas City, Freeport, and the Gulf Coast industrial corridor.
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