An Overview of PSSR Industry Guidelines and Regulations

Even before these regulations existed, industry groups, such as the American Institute of Chemical Engineers Center for Chemical Process Safety (AlChE/CCPS), the Institution of Chemical Engineers (IChemE), the American Chemistry Council (ACC), and the American Petroleum Institute (API), all promoted pre-startup safety review procedures as a sound management practice which can lead to improved process safety and process reliability. 

GUIDELINES FOR PERFORMING EFFECTIVE PRE-STARTUP SAFETY REVIEWS 

For the purposes of this guideline, we will primarily address the needs described in the U.S. OSHA and U.S. EPA descriptions of pre-startup safety review, as well as other good practices. A pre-startup safety review (PSSR) for U.S. OSHA PSM and EPA RMP compliance is required when any change modifies the process safety information. 

So let us define a change. Very simply, it is an alteration to a process that is, not a direct replacement-in-kind. To be considered a replacement in kind, it must be an exact substitute for the originally designed equipment, chemical or technology. 

TABLE 3-1 Global Examples of Pre-startup Safety Review Related Documents  

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