What is pre-startup safety review (PSSR)?

Pre-startup safety review (PSSR) is a process used in industries that handle hazardous chemicals or complex equipment to ensure that everything is safe and ready for operation before starting a new or modified process. It's a systematic review that's conducted before the startup of equipment, systems, or processes that have undergone maintenance (opens in new tab) or significant changes. This includes newly installed changes or inactivity for an extended period of time.

PSSR is particularly important in industries like oil and gas, chemical manufacturing, energy production, and pharmaceuticals, where the consequences of a failure could be severe. It is also mandated by regulatory bodies such as the Occupational Safety and Health Administration (OSHA) under OSHA 29 CFR 1910.199(I). It plays a role in managing risks associated with Management of Change (MOC) processes, and hazard identification techniques like Hazard and Operability Study (HAZOP), and overall compliance with health, safety, and environmental (HSE) standards.

Is PSSR mandatory?

Yes, PSSR is mandatory. Its purpose is to ensure that all safety measures are in place before starting a new process or restarting after significant changes. For example, it is a crucial step in hazardous industries for preventing accidents, protecting employees, and avoiding environmental damage.

Regulatory requirements include:

  • OSHA (opens in new tab): In the U.S., PSSR is required by the Occupational Safety and Health Administration (OSHA) under 29 CFR 1910.199(I), specifically for processes involving highly hazardous chemicals.
  • API (opens in new tab): The American Petroleum Institute (API) also establishes industry-specific safety guidelines, particularly for the oil and gas industries.
  • ISO (opens in new tab): For international operations, the International Organization for Standardization (ISO 45001) outlines occupational health and safety management systems that align with PSSR objectives.
  • EPA (opens in new tab): The Environmental Protection Agency (EPA) monitors environmental safety in processes where emissions and environmental impacts are a concern, making PSSR an essential practice to align with environmental standards.

Key objective of PSSR

The primary objective of PSSR is to confirm that the installation of new or modified equipment complies with safety standards and operational protocols before it is activated. This includes validating that:

  1. All systems are designed, installed, and functioning correctly.
  2. Hazards associated with the new or modified process are identified and mitigated.
  3. Workers are trained and capable of operating or maintaining the equipment safely.

What are the training requirements for PSSR?

In relation to the third objective above, there are essential steps and procedures for teams involved in the PSSR process to be trained on. This includes:

  • PSSR protocols and safety standards.
  • Hazard identification techniques, such as Hazard and Operability Studies (HAZOP).
  • Management of Change (MOC) principles, ensuring everyone understands how modifications can impact overall safety.
  • Emergency response procedures and regulatory compliance are primarily related to OSHA, EPA, and industry-specific regulations.

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PSSR team composition and their roles

A PSSR requires a cross-functional team of experts who bring knowledge and insights to the process. This team typically includes:

Process engineer icon

Process engineers: Evaluate whether the systems are functioning as per design specifications.

Maintenance personnel icon

Maintenance personnel: Ensure the equipment is installed and maintained correctly.

Health safety environmental professional icon

Health, safety, and environmental (HSE) professionals: They identify potential safety and environmental risks and ensure that health and environmental standards are met.

Operations personnel icon

Operations personnel: Provide operational insights, ensuring that systems are safe for day-to-day activities.

MOC coordinator icon

Management of change (MOC) coordinator: Ensures that any changes to the system or process have been properly documented, reviewed, and approved.

What is the PSSR execution process?

The PSSR execution process is a structured systematic approach to ensure that all safety measures, equipment, and procedures are in place and functional before starting or restarting industrial processes. The process is outlined with actions to take for each step in the table below:

Step 1:
Pre-planning and team formation
  1. Assemble a multidisciplinary team: The PSSR team should include process engineers, maintenance personnel, health, safety, and environmental (HSE) professionals, operators' staff, and a management of change (MOC) coordinator.
  2. Define the scope: Determine what equipment, systems, or processes will be reviewed. This typically includes new installations, significant modifications, or restarts after prolonged shutdown.
Step 2:
Review the PSSR checklist
  1. Create or review a detailed PSSR checklist: The checklist will guide the team through all of the safety and operation aspects that need verification, including:
    • Design and engineering specifications
    • Equipment installation and integrity
    • Safety systems and controls
    • Hazard identification
    • Training requirements
Step 3:
Site inspection
  1. Physically inspect the facility: The team conducts an on-site inspection of the equipment, machinery, and process areas.
  2. Verify equipment installation: Ensure all installations are according to design specifications, and the equipment is safely integrated into the system.
  3. Check safety systems: Inspect safety interlocks, alarms, shutdown systems, and other controls to ensure they are functional.
Step 4:
Documentation and procedure review
  1. Verify operating procedures: Ensure that procedures for the operations, maintenance, and emergency shutdown of equipment are accurate and up to date.
  2. Management of change (MOC) review: Confirm that any changes to the process or equipment have been documented, reviewed, and approved according to the MOC process.
  3. Regulatory documentation: Check if all permits, licenses, and regulatory approvals (such as those required by OSHA 29 CFR 1901.119(I), EPA, etc.) are in place.
Step 5:
Operational tests
  1. Conduct functional tests: Test the equipment and control systems to verify they perform as designed under different conditions. Standard practice is testing under normal conditions and emergency situations.
  2. Simulate safety interlocks: Check that safety mechanisms, like emergency shutdown systems, are functioning correctly.
Step 6:
Identification and resolution of action items
  1. Identify any deficiencies or non-compliance: During the inspection, any deviations from design, incomplete installation, or other hazards are noted.
  2. Address deficiencies: Action items are created for each identified issue. These may involve physical repairs, procedural changes, or further training.
  3. Follow-up on open items: Ensure that all action items are resolved before moving on to the next step. The PSSR team must confirm that all safety gaps have been closed.
Step 7:
Team sign-off and close out process
  1. Final review and sign-off: Once all issues are addressed, and the team confirms that the system is safe, team members provide their sign-off.
  2. Document completion of action items: Ensure that all identified hazards, issues, and action items are formally documented and resolved.
  3. Final verification: The team should confirm that all safety systems, controls, and procedures are in place and operational before authorizing startup.
Step 8:
Documentation and record keeping
  1. Store completed PSSR documentation: All checklists, reports, hazard analyses, MOC documents, and action item resolution should be documented and stored for future reference and regulatory audits. Ensure records are kept in accordance with OSHA 29 CFR 1901.119(I).

PSSR workflow diagram

Below is the PSSR workflow diagram stemming from a trigger event. This workflow diagram helps teams understand whether they need to conduct PSSR. You will note that if PSSR is a requirement, the personnel must perform a series of surveys (also known as questionnaires). These questionnaires typically cover various topics to ensure comprehensive safety checks.

Additionally, PSSR short form (seen as SF in the workflow below) refers to smaller changes and modifications to critical safety elements. In contrast, PSSR medium form (MF in the workflow) refers to a more comprehensive change on medium-scale projects. Generally, MF involves more work and a larger team.

PSSR workflow diagram

PSSR ensures the safety and integrity of industrial operations

PSSR is a fundamental practice that underscores a commitment to safety and operational excellence. It's not just nice to have; it's a regulatory requirement for industrial safety and operational integrity. By following regulations and a structured PSSR process, industries can mitigate risks and ensure a safe working environment.

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