29 CFR 1910.119(e)(6) requires that at least every five years after completion of the initial PHA, the PHA be updated and revalidated by a team meeting (e)(4), to assure it is consistent with the current process. Under (e)(7), PHAs and their updates must be kept for the life of the process. OSHA's letters address when the clock runs and what a revalidation involves.
What OSHA Has Said
Sep 20, 2019
Shutdowns don't stop the five-year clock
OSHA said the five-year PHA revalidation clock is not paused while a process is shut down. If the deadline passes during the outage, the PHA must be updated and revalidated before highly hazardous chemicals are reintroduced.
Read OSHA Letter ↗
Apr 16, 2020 · Archived COVID-19 memo
Good-faith delays during the pandemic
During COVID-19 travel restrictions, OSHA told inspectors not to cite an employer whose PHA revalidation consultant couldn't travel, if the employer considered alternatives, used interim protections where possible, and rescheduled as soon as possible. The memo was time-limited and is now archived; it shows the five-year deadline still applied.
Read OSHA Letter ↗
Jun 3, 1993 · Archived
Where the clock started: the original PHA deadlines
In the standard's early years, OSHA explained the phased deadlines for initial PHAs: with one covered process, the PHA had to be complete by May 26, 1994; with two, the higher-priority one by May 26, 1994 and the second by May 26, 1995. Revalidation runs at least every five years from the completion of the PHA.
Read OSHA Letter ↗
Jun 22, 1998
What a PHA revalidation must cover
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.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
Track each PHA's five-year due date from the completion of the last one and plan revalidations well ahead, especially around turnarounds and long outages, because the clock keeps running. If a deadline slips, document why, the interim protections, and the rescheduled date, and never restart a process with an expired PHA. Scope the revalidation to every (e)(3) item, not just a P&ID walkdown.
