Pre Start-up Safety Review (PSSR)

A Pre Start-up Safety Review is a final check prior to starting up the facility, to confirm that the following Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) / Environmental Protection Agency (EPA) Risk Management Program (RMP) requirements are met:

• The process or facility has been built as designed.
• All required documentation and procedures is in place.
• Employee training and competence is complete.
• All action items from the Process Hazard Analysis (PHA) for the activity have been resolved.

PSSR Aproach

Referring to the methodology flowchart opposite, there are seven basic steps considered for conducting a PSSR:

Step 1: Identify trigger events and determine if a PSSR is required

The basis for the PSSR procedure should begin with the identification of the triggering event. That is, identifying if the event in question details any changes being made to an existing process, any new facilities being added to a process or facility, or any non- Process Safety Management (PSM) covered triggered event designated by the facility as benefiting from the review:

• Non-trigger events cover capital projects, start-up post Emergency Shutdown (ESD), routine maintenance, etc.
• Trigger events cover Management of Change (MoC) raised events.

Step 2: Determine the type of PSSR to perform

The basis for the PSSR form selection depends solely on the complexity of the review in question. If the change is straightforward, well understood, and can be signed off with use of minimal PSSR resources yet still be effective; the Short Form will be most suitable.

Nevertheless, if the change is more complex and would benefit from a deeper engineering and process safety related check to provide an additional level of protection – a technique proven to improve safety performance; the Medium or Long form will be more desirable. The purpose of this split is so that a PSSR can be less resource intensive but still provide the required end result. ES have developed a qualitative risk based questionnaire, Q1 and Q2, to evaluate the onerous requirements of the PSSR.

Step 3: Build the PSSR team

The PSSR team size is determined based upon the technical aspects of the change, the nature of the risk and the complexity of the review. The team should consist of a sufficient number of multi-disciplinary experts who have proficiency in some applicable area of expertise relevant to the plant, process or equipment concerned.

Step 4: Conduct the PSSR

The following items are to be administered throughout the PSSR process:

• Assignment of roles for team members.
• Collection of required documentation for the review.
• Regular PSSR team meetings and field inspections as required by the company of the change.
• Identify which items are applicable and which are not.
• Identify and track all relevant action items and verify that all applicable sections of the selected PSSR form have been considered.
• Identify issues that must be corrected before start-up and issues that must be corrected after start-up.

The above approach may differ depending upon the type and complexity of the review.

Step 5: Complete PSSR documentation

This involves a formal completion of the hardcopy form or electronic documentation showing that the PSSR is complete, a final physical review of the facility has been undertaken, indicated action items have been addressed and any post-startup items are tracked.

Step 6: Track any post start-up PSSR action items

All action items, required to be completed after start-up, have been successfully tracked and documented ready for completion.

Step 7: Seek continuous improvements to PSSR programme

Lessons learned, and recommendations are to be advised for continual PSSR improvements.