Pre-startup

How do you resolve pre-startup safety review issues and action items ... 

Details concerning such responsibilities could be provided in the contract or in project correspondence. Chapter 4, Pre-startup and Startup Activities, provides more guidance to consider when performing the PHA. 

The flowchart on the next page shows an overview of steps for the pre-startup and startup phases of a typical tolling process. 

The individuals and firm most familiar with the technology should review the intermediate and final procedures to assure both safety and commercial interests are satisfied. In many batch operations the procedure(s) can be a substantial portion of the process technology package. The procedures represent both a major safety system as well as a propriety technology. The pre-startup review should assure both PHA related and other changes proposed to the procedures have been approved and implemented. 

Startup This includes procedures addressing pre-startup operations, initial startup, startup following turnaround and startup after emergency shutdown. 

If operating procedures need to be developed from scratch, this could account for a considerable portion of the pre-startup work. If current, valid standard operating procedures exist, and the toll is only introducing a new set of batch instructions, the task becomes simpler. However, it is recommended that the new batch instructions are reviewed simultaneously with the existing startup, shutdown, normal and emergency operating procedures for the equipment to help ensure potential process deviations are examined and addressed. 

The question to answer for this pre-startup task is Who needs training for this process and to what level of detail One method to analyze training needs is offered by the Instructional Systems Design (ISD) technical training model. It points to the job task analysis method mentioned previously (Appendix D, ISD Model and Job Task Analysis Techniques) to identify procedure titles as a first step for determining which job positions require specific knowledge and skills. 

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 ... 

Example 4-1. Pre-startup safety review completion form... 

TOLLER CD. iHOiirraiuiiuK Pre-Startup Safety Review Form Form No. PSMADM09.501 Rev. 2 ... 

Some toll processes lend themselves to test runs in the pre-startup phase. Actual materials for the toll may be used in the test or substitute materials, typically with low hazard potential, are often used to simulate the charging, reaction, and physical changes to be accomplished in the toll. Flow control, temperature control, pressure control, mixing and transferring efficiency can be measured. Mechanical integrity can be verified in regard to pumps, seals, vessels, heat exchangers, and safety devices. 

Some of the pre-startup activities may need to be revisited when physical increases in volume and changes to equipment are planned. A PHA may need to be revalidated prior to implementing such a change to evaluate any secondary issues it could cause. 

The tolling team has analyzed the hazards, addressed the risks and modifications using a management of change system, revised and written procedures, trained the workers, performed a PSSR, and completed any required test runs. The pre-startup phase is complete at this point. 

A toller may be operating the first scale-up of a process that has previously only been produced in pilot quantities. This pre-startup situation benefits when special concerns related to a scale-up are monitored. 

Did the Process Safety Information Change O YES O NO ( items indicates PSI) (If YES, initiate PSM-ADM-08, Pre-Startup Safety Review)... 

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