Most PHA recommendation dispositions in refining live in a free-text 'Basis' field or a retired engineer's memory. The ones that matter — the repeat failures, the pump that trips monthly, the alarm that floods every unit upset — are the ones where the rationale for not implementing decays fastest. Sovel surfaces them, turns them into governed Decision Cards — grounds, evidence, qualified sign-off — and keeps them sealed.
P-204A trips at 03:00. Day shift restarts it. It trips again the next month, and the month after. The real fix lives in a single Slack message from a process engineer who left two years ago — outside the CMMS, outside the reviewer's reach, outside the audit trail.
K-101 surges three times in six months. Each event reads as a low-suction-pressure trip in the CMMS. The shift logbook from event two names the upstream cooling-tower fan. The third reviewer never sees the second log — different shift, different system, no link.
The FCC unit goes upset and generates 740 alarms in 10 minutes — well above the EEMUA 191 ceiling. To keep the unit in service, the operator silently disables three nuisance interlocks. The interlock-disable is the load-bearing knowledge. It lives in nobody's procedure.
Process Safety Management of Highly Hazardous Chemicals — sub-paragraphs Sovel maps against.
Reviewer inbox surfacing a repeat-failure cluster on FCC slide-valve P-204. Each row is a knowledge-risk finding Sovel proposes; the named reviewer approves, defers, or rejects. Approval emits a verify-in-place record that satisfies PSM §1910.119(l) Management of Change closure.
Start with a conversation about the declined or deferred PHA recommendations you already have to defend. From there, a short Decision-Card Sprint — scoped together — turns them into governed records mapped to the PSM 1910.119 sub-paragraphs your safety lead already audits against.