Pre-startup Safety Review PSSR

For new processes, the company will find a PHA helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process is enhanced by making use of the PHA recommendations before final installations are completed. P IDs should be completed, the operating procedures put in place, and the operating staff trained to run the process, before startup. The initial startup procedures and normal operating procedures must be fully evaluated as part of the pre-startup review to ensure a safe transfer into the normal operating mode. 

For existing processes that have been shut down for turnaround or modification, the company must ensure that any changes other than replacement in kind made to the process during shutdown go through the management of change procedures. P lDs 

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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... 

The Project Manager should maintain and issue a action plan summary until all items are closed out. The HAZOP or What-If Addendum report is usually prepared from the action plan summaries. Items which are not closed out prior to the facility or project start-up should be addressed as part of the Pre-Startup-Safety-Review (PSSR). A copy of the action plant should be made available to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions. 

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. 

The fourth pass of the PHA is done after construction and before startup begins. This is a physical check of the facilities to be sure the plant has been constructed as per the detailed design. This analysis is usually called the Pre Startup Safety Review (PSSR). This review would also include checking that all control logic and safety protective devices are appropriately calibrated and are working properly. 

ANSI/ISA-84.00.01-2004-1 has specific requirements for conducting functional safety assessments during the SIS lifecycle. It also includes requirements for the composition of the assessment team. The one mandatory assessment is at Stage 3 of the SIS lifecycle. This assessment is included in ANSI/ISA-84.01-1996 and OSHA 1910.119, but it is called the Pre-Startup Safety Review (PSSR). The standard simply clarifies the PSSR, as it pertains to the SIS. The major difference is that ANSI/ISA-84.00.01-2004-1 requires the inclusion of an independent, senior, competent person on the team. ISA-TR84.00.04-1, Annex C, has additional discussion concerning this requirement. 

In its most generic application to manufacturing, the term pre-startup safety review (PSSR) means the following ... 

For the purposes of this guideline, we will primarily address the needs described in the U.S. OSHA and U.S. EPA descriptions of pre-startup safety review, as well as other good practices. A pre-startup safety review (PSSR) for U.S. OSHA PSM and EPA RMP compliance is required when any change modifies the process safety information. 

In order to manage a process safety and environmental risk program element like pre-startup safety review (PSSR), it is essential to understand the work process. As we have discussed, different facilities have different levels of risk, levels of resources, and organizational cultures to consider. If covered under OSHA PSM or EPA RMP, each facility must be able to demonstrate compliance, but how it is specifically accomplished is open to interpretation. 

An effective pre-startup safety review (PSSR) is centered on the tools a company provides to assist its staff in evaluating the safety and operational readiness of the trigger events it evaluates. One tool many companies provide is a PSSR checklist or electronic database of items to consider. This chapter examines options and considerations for compiling the items applicable to a facility. 

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. 

Pre-startup safety review (PSSR) A final check, initiated by a trigger event, prior to the use or reuse of a new or changed aspect of a process. It is also the term for the OSHA PSM and EPA RMP element that defines a management system for ensuring that new or modified processes are ready for startup. 

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