Performing a Pre-startup Safety Review

As a good practice, a PSSR team could be formed as a part of new facility construction. It is recommended eveiy PSSR involve at 

If a PSSR is extensive, the PSSR team should include a toller company engineer and an engineer from the client. In addition, an operations supervisory representative and operations personnel with appropriate knowledge and skills along with a maintenance and safety representative may also be included on the team. The PSSR leader must ensure enough manpower and expertise is available on the team to review the new facilities and major modifications thoroughly. 

The PSSR team will confirm that the following requirements have been met before materials are introduced into the new or modified toll process. 

Construction and equipment meet the design specifications. Obtaining field verification or performing document review for the new or modified process can validate design specifications for construction and equipment. If a change is not physical (such as a setpoint for an interlock shutdown), the method for the change and its anticipated effects should be reviewed. 

A PHA has heen performed for new facilities. The management of change documentation packages and referenced documents should indicate when a process hazard analysis was performed for the modification or new facility. The PSSR Team should verify all of the PHA recommendations have been implemented or otherwise resolved before the toll process can be judged ready to operate. 

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Pre-Startup Safety Review. Employers must perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. The safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process ... 

Prior to startup of new facilities or facilities that have undergone changes, a Pre-Startup Safety Review (PSSR) must be performed by a supervisor of the affected process unit. If the supervisor is assured that construction and equipment are in accordance with design specifications and that affected procedures, process safety information, and training are updated, he completes the PSSR Form 11—3. If any of the pre-startup requirements have not been met satisfactorily, the supervisor sees to it that the deficiencies are corrected and... 

On a broader scale, effective PSSR supports any mature, well-designed PSM program by keeping the total program robust and vibrant in the face of change. The CCPS booklet The Business Case for Process Safety summarizes the benefits of process safety - and these same benefits are supported by performing effective pre-startup safety reviews ... 

For all readers, this chapter introduces a key aspect for performing effective pre-startup safety reviews - using risk to determine the type or complexity level of PSSR to perform. 

A functional safety assessment (also called a pre-startup safety review) was performed prior to startup of the process see ISA-84.01-2004, Part 1 clause 5.2.6.1. The overall objective of the functional safety assessment was to ensure that the SIS would operate in accordance with the requirements defined in the safety requirement specification so that the SIS can safely move from the installation phase to the production phase. 

A pre-startup safety and environmental review should be performed on all modified or newly constructed facilities. 

The safety impact of design and construction changes to a project performed after the final HAZOP or What-If reviews and prior to commissioning are identified as part of the facility Pre-Startup-Safety-Review (PSSR) and Management of Change (MOC) procedures. 

Pre-Startup Safety Review (PSSR) Audit check performed prior to equipment operation to ensure adequate PSM activities have been performed. The check should verify (1) Construction and equipment is satisfactory, (2) Procedures are available and adequate, (3) A PHA has been undertaken and recommendations resolved, (4) The employees are trained. 

There are many benefits to be gained from performing pre-startup safety review for your processes. A simple list includes ... 

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 basic algorithm steps below describe performing a risk-based PSSR. They will be expanded upon in Chapter 5 - The Pre-startup Safety Review Work Flow Process. 

It could be easy to overlook this aspect of the pre-startup safety review (PSSR) program at a facility. However, PSSR performance can benefit from the same techniques used to improve product quality and productivity performance for a company. In actuality, the return on investment could even be greater from seeking continuous improvement for the PSSR element if it ensured new process aspects were implemented more safely and in a way that reduced rework and poststartup problems. 

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