A Simple PSSR

Here is an example of applying the algorithm presented previously in Section 4.2.2 to a lower risk trigger event. We will use the risk matrix to determine the potential impact. 

The trigger event for this example is the addition of a check valve to an existing bypass line. 

Become aware of a trigger event (a change in regard to process safety or other organizationally defined standard). 

Assess the event s need for management of change and pre-startup safety review. 

Apply a qualitative risk-based analysis to the event to determine the event s potential severity and likelihood. 

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If any items are answered yes, in the above example of a risk-based approach, then study the change in detail and plan to perform a more complex PSSR rather than a simple PSSR. Additional considerations are provided in Chapter 4-A Risk-based Approach to Pre-startup Safety Review. 

The typical effort for a simple PSSR is for review of the documentation associated with the change or trigger event, a physical walkthrough of the change or other verification of proper installation, then hardcopy or electronic signatures allowing any other preparations in accordance with plant policy or regulatory requirements for startup to proceed. 

A simple PSSR is recommended for this event. (NOTE It is never incorrect to use the complex PSSR approach and complete the long form for any trigger event.)... 

Once the PSSR team has evaluated the risk-based aspects of the trigger event and determined a simple PSSR is suitable, the resulting software screens can be collapsed to show only those fields required. 

This book is intended for anyone interested in developing a new PSSR program or upgrading an existing one. It can also help as a simple comparison tool to see where a mature program already uses some of the good practices or to help reinforce or improve upon the current methodology. 

Here is a simple test to help determine when a PSSR is required for a triggering event at a facility ... 

The term simple should not be misunderstood as we use it in this book. It does not mean this category of PSSR is less important than a complex PSSR. It is intended to indicate the level of effort needed is well understood and fairly straightforward. Whenever we use the terms simple PSSR or short-form PSSR, they indicate a less resource-intensive approach to verifying readiness for startup when the trigger event has a lower level of risk. 

Some companies use different levels of firequency and severity and others may also look at other dimensions separately like capital expenditure levels. Often, the simple PSSR is reserved only for lower risk ranking. Medium to high would indicate the need for a complex PSSR. 

Another tool used to make this simple PSSR versus complex PSSR riskranking decision is a risk questionnaire. In this case, a facility applies a set of standards against which each PSSR is evaluated. It may be performed ... 

If the change management review Indicates the process safety information must be changed, ask the following questions about the change to determine if it is classified as a simple or complex PSSR ... 

For example, a two-person team, the PSSR team leader and one member, may be all the signature authority needed to sign off on a PSSR short form if signatures are required by your site policy. An example form is shown in Table 4.2 -Example short form for lower risk / simple PSSR. 

Here are two examples of using a risk-based approach in PSSR. The first uses the simple PSSR short form. The second example discusses using the PSSR long form. 

Identifying the roles that personnel must fill to perform any PSSR, whether a simple or a complex PSSR, is essential. People like to know exactly what the requirements are for their roles in any task. 

A PSSR team will be formed as a part of new facility construction and when any trigger event modifies the process safety information for a process. Many companies require that the team will have at least one member besides the PSSR team leader. However, some companies do allow for one person to perform the PSSR for lower-risk (simple) PSSRs. 

For some simple PSSRs, the team may only need access to the work order for a small change. For more complex PSSRs, the team may need to see P IDs, schematics, MSDS, operating procedures, maintenance procedures, and safe work practices. 

Some companies require PSSR team signatures as a way of encouraging ownership of the PSSR authorization to start up the equipment involved in the trigger event, whether a simple item or a complex modification. In any case, this is typically the last step in the PSSR work process. 

Once the PSSR team is satisfied with their review, a form such as Example 4-1, Pre-startup Safety Review Completion Form can be used to capture their approval for startup. For simple changes, this one-page form may be all that is required. In the case of extensive modifications, a detailed checklist of items examined by the team may accompany this form. It could include unsatisfactory findings as well as respective recommendations. If recommendations were made, these must be prioritized. Some may need to be resolved before startup others may be appropriately addressed after processing has begun. Some items reviewed by one company for extensive modifications and logged in addition to the one-page form are ... 

The following example of a basic priority risk-ranking matrix system is provided to display one tool for determining whether the change or trigger event is simple - and able to use a short form PSSR - or more complex, thus in need of a long form PSSR. 

Some hardware changes or trigger events can be simply verified as the installation progresses. A PSSR review of a hardware item might be as simple as checking the work permit and walking into the unit to verify the piping, vessel, valve, or other item is in place and matches the specifications. 

Here is where the risk-based approach necessitates a first look at the nature of the trigger event. By following some of the guidelines in Chapter 4, the type of PSSR to design is relatively easily divided into simple or complex - that is, a short form or a long form respectively. However, when the PSSR long form is indicated, there are numerous decisions to make about the pre-startup safety review s needs. 

PSSR Short Form - This form is to be used for simple modifications where a PSSR is required due to minor changes in process safety information. A guideline for when to use this form is if a MOC for the modification s hazard review was able to be completed without using a process hazard analysis. 

On the PSSR short form for simple trigger events, a date in the date resolved box and initials in the initials box indicates that an item is satisfactory or that the issue has been corrected or resolved or a recommendation is closed. 

The most basic approach to an electronic PSSR checklist is to create a word processing software or spreadsheet software template form for the simple and complex checklists. If desired, the simple and complex items can be built together into one document as the instructions might be to either mark or delete all non-applicable items from the file customized for the specific PSSR trigger event. 

An example of a possible resulting electronic checklist screen is shown below. In this example, a very simple trigger event needed only two team members to review the items. As each major category of the PSSR database items was marked not applicable, it collapsed to show this. For the one major category selected, only the one applicable sub-item (P ID revision to show the local gauge s range change) remains visible and records the PSSR completion. 

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