PHA Recommendations — Resolution and Documentation — OSHA Letters of Interpretation

In a letter on blast-resistant structures, OSHA said (e)(5) requires PHA findings to be addressed "promptly": if a PHA shows a structure can't protect workers from an explosion, the employer must remedy it, by strengthening the structure to RAGAGEP, relocating workers, or controlling the hazard at its source, and document how the deficiency was resolved.

A law firm asked OSHA to review its PHA revalidation procedure. OSHA said (e)(6) only specifies that revalidation happen at least every five years by a team meeting (e)(4), and that it does not require an all-new PHA. But the revalidation must at least: evaluate the existing PHA against every (e)(3) item; confirm changes since the last PHA went through MOC and are reflected; confirm all PSI is complete and current, not just P&IDs; verify procedures are adequate and followed; confirm prior recommendations were documented and implemented; and review every incident investigation report under (m) and incorporate it. The revalidation must be documented.

OSHA's RAGAGEP memo tells inspectors that when employers specify safeguards based on PHA, incident investigation, or MOC findings and fail to implement or complete the documented actions, the failure may be cited under the relevant provision, such as (e), (l), or (m).

OSHA's letter on (e)(3)(vii) included a sample risk matrix showing how a PHA team can rank each hazard by consequence and likelihood to prioritize action. In OSHA's example legend, the highest-risk class must be mitigated within two weeks or the process shut down. The example is illustrative, not a required timeline.