Double Checking Management of Change

In the case of management of change, the pre-startup safety review activity is focused on a trigger event that is a change - something not in the same condition it 

In these cases, the role of the PSSR program is to provide a second layer of protection around the management of change element. Some companies even bundle these elements together in one MOC/PSSR administrative-level management system procedure. 

Essentially, in terms of applicable regulatory requirements, PSSR is verifying the four PSM/RMP requirements, which is essentially that the MOC process was followed. How can we make sure we have addressed these requirements in a way that adds value to the process By using PSSR thoroughly and systematically, even when the benefit may not be explicit. 

For non-change type trigger events, PSSR is verifying that the process is safe for startup, all maintenance has be completed, and other facility requirements have been met (for example, a PSSR following a maintenance turnaround or after an emergency shutdown). Again, the PSSR provides a second layer of protection that all other policies and procedures are complete. 

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