“Safer technology and alternatives” refer to risk reduction strategies developed using a hierarchy of controls that are considered inherent, passive, active, and procedural. This strategy can be applied initially to all design phases and then continuously throughout a process’s life cycle. STAA includes concepts known as inherently safer technologies (IST) or inherently safer design (ISD), which reduce or eliminate the hazards associated with materials and operations used in a process. IST, ISD, and inherent safety are interchangeable terms that are used in the literature and in the field. The four major inherently safer strategies are:
- Minimization–using smaller quantities of hazardous substances;
- Substitution–replacing a material with a less hazardous substance;
- Moderation–using less hazardous conditions or a less hazardous form, or designing facilities that minimize the impact of a release of hazardous material or energy; and
- Simplification–design facilities to eliminate unnecessary complexity and make operating errors less likely.
Process Hazard Analyses (PHAs) are already part of the existing rule requirements. As part of the PHA, qualifying programs in three industry categories (paper manufacturing; coal and petroleum products manufacturing; and chemical manufacturing) are required to thoroughly evaluate safer technology and alternatives when conducting their Process Hazard Analysis, however implementation is not mandatory. These categories were selected because of highest frequency of