The rule states that I have to update my RMP whenever I revise a PHA. What constitutes a revised PHA? Every time I go through management of change procedures I make a notation in the PHA file for the process, but would that constitute a revised PHA if the change did not affect the validity of the PHA?
All changes (except replacement in kind) are subject to the management of change of procedures. When processes undergo minor changes (e.g., minor rerouting of a piping run), information is typically added to a PHA file to reflect the change, even though the validity of the PHA is not affected by the modification. These minor changes and the addition of information about the change to the PHA file are not considered a 'revision' of the PHA under the part 68. Major changes that invalidate a PHA, leading you to 'update' or 'revalidate' the PHA so that it accurately reflects the hazards of the process, are considered a revision of the PHA under part 68.