November 11, 2020
Companies have conducted Pre-Startup Safety Reviews (PSSRs) as part of Management of Change (MOC) activities for a long time. While required by law in the US in highly hazardous industries to meet regulatory requirements such as 29 CFR 1910.119, PSSRs are much more than an MOC tool.
A PSSR is a form of an audit. It is meant to keep field personnel safe in both new facilities and modified facilities when the modification is significant enough to require change in the Process Safety Information (PSI). In fact, standalone PSSRs can be triggered by a number of scenarios, including but not limited to:
Often, best-in-class companies ensure that any post-commissioning trailer items (e.g., P&ID updates) get completed within 180 days.
Government agencies require PSSR due to a number of industry incidents where lack of oversight in the review process, communication, or field installation resulted in the release of toxic chemicals, fires, or explosions. History has shown that approved chemical process changes can result in incidents due to errors where specifications, methods, and construction are not executed per requirements.
To establish, implement, and maintain PSSRs in compliance with OSHA’s Process Safety Management (PSM) Regulation 29 CFR 1910.119(i) and the EPA’s Risk Management Program (RMP) Rule 40 CFR 68.77, companies must ensure safety through confirmation that:
A PSSR is required per U.S. OSHA PSM / EPA RMP compliance when any change modifies the PSI, including but not limited to:
Elements of an effective PSSR procedure should ensure:
A PSSR system provides numerous benefits to an organization by integrating the work of all the different disciplines involved in a team activity, in terms of greater profitability, safety, and other enhancements. PSSRs allow for more power in identifying and resolving hazards in a team environment, avoiding false starts that result in unit shutdowns and rework or repairs.
Operational Sustainability® (OS) offers a variety of technical standards for PSSRs specific to different applications, including Policies, Procedures, and Field Guides. PSSR is generally facilitated by a number of checklists that are completed by several areas of expertise. This includes engineering, operations, maintenance, electrical, instrumentation, safety, environmental, and other disciplines.
OS also offers the OESuite® PSSR Module as part of our integrated comprehensive mobility platform. Users can create checklists, ensure required personnel are aware of hazards and properly trained before startup, and quickly access and approve PSSR checklist items to resolve actions and findings.
To learn more about the OS approach to effective PSSRs, download our PSSR brochure.