1. The PHA has not been updated and revalidated by a team every five years after the completion of the initial
PHA to assure that the PHA is consistent with the current process. [68.67(f)]
2. The owner or operator has not retained PHAs and updates or revalidations for each process covered, as well as the resolution of recommendations for the life of the process. [68.67(g)]
3. The owner or operator has not followed recognized and generally accepted good engineering practices for inspections and testing procedures. [68.73(d)(2)]
4. The owner or operator has not ensured the frequency of inspections and tests of process equipment are
consistent with applicable manufacturers recommendations, good engineering practices, and prior operating
experience. [68.73(d)(3)]
5. The owner or operator has not documented each inspection and test that had been performed on process
equipment, which identifies the date of the inspection or test, the name of the person who performed the
inspection or test, the serial number or other identifier of the equipment on which the inspection or test was
performed, a description of the inspection or test performed, and the results of the inspection or test. [68.73(d)(4)]