Prestartup safety review

Process and Equipment Integrity—Among the things to be considered here are reliability engineering, materials of construction, fabrication and inspection procedures, installation procedures, preventive main-tainence, process, hardware and systems inspections and testing (prestartup safety review), maintainence procedures, alarm and instrument management, and demolition procedures. 

This allows funds to be spent for engineering, the development of training, etc. However, startup cannot proceed until the Prestartup Safety Review (PSSR) is successfully completed. 

Some of the elements in Table 1.4, such as Management of Change, are identical to those in Table 1.3. Others are modified—e.g.. Prestartup Safety Review becomes Operational Readiness. But some of the elements in Table 1.4, such as Measurements and Metrics, are completely new. One of the topics in the original OSHA list— Trade Secrets— has been removed. 

If the other elements of the PSM program have been properly implemented, particularly the MOC and Prestartup Safety Review (PSSR) elements, then the hazards analysis validation should be quite straightforward. If the first hazards analysis was a HAZOP, it is often appropriate for the subsequent analyses to use either the What—If or the Checklist methods. Doing so will save time, and will probably provide for a superior analysis because the team members will be using a fresh way of thinking and will be less likely to be bored. 

The employer shall perform a prestartup safety review for new facilities and far modified facilities when the modification is significant enough to require a change in the PSl. 

The prestartup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process ... 

After a change has been implemented following the use of the MOC process, it is important to conduct an operational readiness or prestartup safety review (PSSR) immediately prior to starting the changed equipment or operations. An important part of any PSSR is to ensure that the operating and maintenance procedures have been updated, and that the affected technicians have been trained. 

The purpose of a prestartup review (PSR) is to ensure that initial start-ups, or start-ups following major project work, proceed safely and smoothly. Alternative names for the same activity are prestartup safety review (PSSR) and operational readiness review. As with most process safety activities, a PSR will generally be performed by a small team made up of representatives from operations, maintenance, engineering, and safety. 

The Operations Manager will have to operate the facility after the change is made. He will be closely involved in the PHA, and will supervise the Operational Readiness/Prestartup Safety Review. 

The use of turnover packages improves both efficiency and safety. Efficiency is improved because the process of turning over the system to operations can start quite early on, thus saving time. Safety is improved because there is a clear definition of boundaries, with a corresponding understanding of who is responsible for what. Whenever the operations department is about to assume responsibility for a turnover package, a prestartup safety review (PS SR) can be carried out on the contents of that package. 

Under the requirements for Prestartup safety review, for new facilities and for significant modifications, the employer is required to provide a process hazard analysis—among other considerations. In no place in the OSHA rule is there mention of occurrence probability. This appears in the preamble ... 

Prestartup review Some major engineering and equipment changes were made to the piatform in the day before the event Before equipment is started, the system should be checked with a Prestartup Safety Review to make sure that all changes have been properly managed and the system is safe to operate. 

The SEMS requirements to do with prestartup safety reviews are described and discussed below. 

WHAT ARE THE BENEFITS OF PERFORMING PRESTARTUP SAFETY REVIEWS ... 

A recent incident that occurred during a post-turnaround startup at a refining facility was investigated by the U.S. Chemical Safety Board (CSB) and the company involved. Both reports recommendations imply that thorough prestartup safety review implementation could have mitigated or completely avoided the incident. 

A RISK-BASED APPROACH TO PRESTARTUP SAFETY REVIEW... 

Based upon the descriptions in previous chapters, we know the definition of a prestartup safety review is ... 

The term chemical processing industry (CPI) is wide ranging in its scope. Other manufacturers not included within the grouping CPI also can benefit from prestartup safety reviews. The PSSR items used to spur thorough review for a refinery may be very different from those used for a pharmaceutical manufacturer, semiconductor manufacturer, or a coatings or specialty chemical manufacturing facility. 

Conduct prestartup safety reviews of all newly installed or modified equipment. 

An Operational Readiness/Prestartup Safety Review may be needed, particularly if the design of the system was changed in any way or if process conditions will change following the maintenance work. For large maintenance tasks, a turnover package may be required. (Information on these topics is provided in Process Risk and Reliability Management.)... 

Process safety focuses on process-related failures such as runaway chemical reactions, pipe ruptures, or vessel overflow. Such events may happen only rarely, but they can have catastrophic consequences. They are generally caused by failure to properly implement management systems such as operating procedures, mechanical integrity, training, prestartup safety reviews, and management of change. 

This section of SEMP discusses the requirements of a prestartup safety review. It refers to APPI RP 14 J and to Appendix B of the standard. 

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