Pre-Start up Review

This requirement is intended to be a redundant follow-up to Management of Change, discussed in the previous section. It provides for an independent recheck that changes are in condition to be operated prior to startup. In complex chemical plants and refineries, it is a vital redundancy; in ammonia refrigeration plants, a simple review by a manager that the provisions of Management of Change are complete should be sufficient.

The Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) element and the corresponding Environmental Protection Agency (EPA) Risk Management Program (RM Program) regulation element relating to Pre-Startup Safety Review (PSSR), is to help ensure that certain important considerations have been addressed before hazardous materials are introduced into the process or the modified section(s) of an existing process. This helps ensure that adequate safety measures are in place and are operational. The pre-startup safety review procedure is typically followed in conjunction with the Management of Change Procedure. The pre-startup safety review must be completed prior to the introduction of hazardous materials into the process and must confirm the following:

Construction and equipment is in accordance with design specifications; Safety, operating, maintenance, and emergency procedures are in place and adequate; For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup;

For modified facilities, they meet applicable management of change requirements; and Training for each employee involved in operating the process has been completed.

The term Prestartup Safety Review (PSSR) first received prominence in the process industries with the introduction of the Process Safety Management (PSM) regulations. In the United States two federal agencies, the Occupational Safety & Health Administration (OSHA) and the Environmental Protection Agency (EPA) require that companies conduct prestartup safety reviews following changes to the process or the way in which the process is

operated. The wording of the two standards regarding PSSRs is virtually identical. However the industries that they cover and their respective reporting requirements differ slightly. The fundamental purpose of a prestartup safety review is to ensure that any changes that are made to a facility or item of equipment meet the original design or operating intent and that the process/facility is not required to operate in an unsafe condition. A PSSR aims to catch any changes that may have crept into to the system during the detailed engineering and construction phases of a project. A PSSR covers not only equipment, but also soft issues, such as operating procedures and training. PSSRs play a particularly important role in large projects because such projects all too often fall behind schedule and/or run over budget, thus creating pressure on the project team to eliminate or postpone the installation of any items that are not absolutely necessary for the start-up. If not controlled properly, this can lead to corner-cutting - either intentional or inadvertent - which may then jeopardize safety. By carrying out a PSSR, the operations and maintenance departments have the authority to refuse to accept responsibility for a plant or item of equipment that they judge to be unsafe. In effect, a prestartup safety review provides a breathing space for everyone to make sure that the plant that they are about to start is safe and operable. It is not the purpose of a PSSR to replace this normal punching out of a new or modified facility. Indeed, one of the purposes of a PSSR is to make sure that routine checking processes are in place, and that they are followed. Nor is a PSSR a last-minute hazards analysis. The PSSR team should check that a hazards analysis was carried out on the proposed changes, and that all the findings were implemented or closed out in a professional manner, but the PSSR does not aim to identify new hazards.

Written procedures do not exist Pre-Startup Safety Review documentation is not completed or kept on file following the implementation of the MOC procedure Documentation is not completed, and signedoff, until after start-up.