Pre-Startup Review

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. 

Maintenance (Mechanical Integrity) —Pre-Startup Review —Management of Change —Safety Audits — Accident Investigation... 

Under the management of change section of the PSM standard employees are required to develop and implement documented procedures to manage changes in the process chemistry, process equipment, and operating procedures. Before a change occurs (except for replacement-in-kind), it must be reviewed to ascertain that it will not affect the safety of the operation. After the change has been made, all the affected employees are trained, and a pre-startup review is conducted. 

It is interesting to note that facilities that are classified as Program 2 facilities do not have to include the management of change, pre-startup review, employee participation, hot work permit, or contractors elements of PSM into their RMP. 

Suspended items from Pre-Startup Review are complete. 

If the change is approved, startup cannot proceed until the Pre-Startup Review is completed (line 8) and the SLS or DH signs off on line 9. To proceed with the change any affected documentation is updated, and the change is engineered and constructed. Any requirements identified for later completion are suspended as required. People whose job tasks will be affected by the change are informed and trained in the change prior to startup of the process. Individuals who are off shift or absent are trained upon resumption of their job responsibilities. 

Suspended items from Pre-Startup Review are complete. Signed (SLS or DH) Date,... 

The scope, organization, format, review method, final report, and frequency are discussed as they apply to research projects. The concept of tailoring the review method to the degree of hazard involved is explained and an example of a Process Hazards Review and a Pre-Startup Review/Process Hazards Audit are given. 

The ultimate objectives of the Du Pont Company s Process Hazards Reviews, and Pre-Startup Reviews/Process Hazards Audits, are to ... 

The terms Process Hazards Review and Pre-Startup Review/Process Hazards Audit have been mentioned and are defined. 

Process Hazards Reviews comprise formal committee meetings where hours are spent intensively examining, by one of the methods described later, a chemical reaction or process, with a report, documentation, and follow-up. Pre-Startup Reviews/Process Hazards Audits are no less intensive, but the time spent is less, because the complexity of the process or equipment being examined is less. Reports, documentation, and follow-up are also a part of the Pre-Startup Review/Process Hazards Audit. An equipment acceptance safety inspection would be considered a Process Hazards Audit. 

These guidelines are not meant to be all inclusive and there are cases where a combination of less hazardous conditions can create a need for a Process Hazards Review or a Pre-Startup Review/Process Hazards Audit,... 

After the review method is chosen, the responsibility for holding the PHR or Pre-Startup Review falls to the line organization who contact the Process Hazards Review Committee. At the Experimental Station, each resident Laboratory or Department has a committee appropriate to its needs. In each case, the committee chairman is in a management position and can command the resources necessary to review the process or equipment successfully. It is the chairman s responsibility to assure that the review is intensive and covers all aspects of the process or equipment. The chairman also serves as the Laboratory s liaison with the Site Process Hazards Management Committee. 

The next example is of a Pre-Startup Review or a Process Hazards Audit held on a piece of purchased processing equipment, a Haake Rheocord Torque Rheometer and Laboratory Twin-screw Extruder. The organization responsible for this extruder has a standard checklist of eleven pages of items to be considered by the technical person or persons in charge of the equipment or process, before the review is held. Copies of the completed checklist are then sent to each committee member before the meeting for review. Generally, in a review of this type, the group will convene at the location of the equipment rather than in a conference room to go over the material provided. In this case, the committee consisted of ... 

A complete discussion of all the checklist items in this Pre-Startup Review would not be possible in this paper but consideration was given to all of them. As a result, a memorandum was issued by the technical personnel to the committee outlining the recommendations made. These recommendations covered five... 

The date on which the proposed changes would become effective and, if a temporary change, the date on which the modified process would revert to the original process. If the changes are to be permanent, the Pre-Startup Review procedure should be implemented. Many companies require that the modified process be analyzed for hazards, prior to startup, using a Process Hazards Analysis method that would be consistent with the inherent or demonstrated hazards. 

Physical inspection to ensure readiness of equipment and persoimel prior to implementation (pre-startup review)... 

Dr Jack Chosnek expresses concerns for three elements of MOC for success in his paper Managing Management of Change. (Reference B) Chosnek emphasized, Technical Description , Safety Analysis and Pre-Startup Review. His words on Safety Analysis and its impact are quoted here ... 

Develop an ongoing measurement and feedback system. Drive the system with upstream activity measures that encourage positive change. Examples include the number of hazards reported or corrected, numbers of inspections, number of equipment checks, JHAs, or pre-startup reviews conducted [7]. 

However, the contract workers may be required to participate in other activities, such as Pre-Startup Reviews. 

Pre-startup review. This is required for both new and modified facilities. It should cover design, procedures, employee training, and PUA. 

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