Pre-Startup Safety

PrH A improves the safety, reliability and quality of the design and construction of a new or old process. P IDs must be correct as constructed operating, startup and shutdown procedures must be validated, and the operating staff must be trained before startup. Incident inr estigation recommendations, compliance audits or PrHA recommendations need resolution before startup. 

The first line of defense is operating and maintaining the process as designed, to keep ihe hazardous material contained. 

The second line is the controlled release of materials through venting to containment/ confinement or through filters, scrubbers, flares, or overflow tanks. 

The third line includes fixed fire protection systems (sprinklers, water sprays, or deluge systems, monitor guns, etc.), dikes, designed drainage systems, and other systems that control or iiiitigaic ha. ardous releases. 

Equipment used to process, store, or handle highly hazardous chemicals must be designed constructed, installed and maintained to minimize the risk of release. A systematic, scheduled, test and maintenance program is preferred over breakdown maintenance that could compromise safety. Elements of a mechanical integrity program include 1) identification and categorization of equipment and instrumentation, 2) documentation of manufacturer data on mean time to failure, 3 ) test and inspection frequencies, 4) maintenance procedures, 5) training of maintenance personnel, 6) test criteria, and 7) documentation of test and inspection results. 

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

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 ... 

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

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

Process, hardware, and systems inspections and testing (pre-startup safety review) Maintenance procedures Alarm and instrument management Demolition procedures... 

Pre-Startup Safety Review Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emergency Planning and Response Compliance Audits Trade Secrets... 

A pre-startup safety review is a special safety review that is conducted after a modification to the process or operating conditions has been made and before the startup. In this review a team of reviewers ensures that (1) the system is constructed in accordance with the design specifications, (2) the safety, maintenance, operating, and emergency procedures are in place, (3) the appropriate training is completed, and (4) the recommendations from the PHA are implemented or resolved. 

Confirm the facility is ready for Pre-startup safety start-up review... 

Restart criteria recommendations should receive the same degree of scrutiny as the final and formal recommendations. The manage-ment-of-change and pre-startup safety review implications of each restart recommendation should he considered and evaluated for possible adverse consequences. Some common changes encountered in restart criteria recommendations include ... 

The investigation team members were consulted frequently during the design and installation of the repairs for restart. Several team members participated in the recommended process hazards analysis and the pre-startup safety reviews. 

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