PSSR is an abbreviation for Pre-startup safety review, an element in OSHA’s Process Safety Management (PSM) regulations. These regulations require that the employer shall perform a PSSR for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
Process Technical Services can provide experienced and qualified personnel that have either lead or participated as a member of PSSR teams, and are available to help clients.
OSHA suggests that for new processes, the employer will find a PHA (Process Hazards Analysis) helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process will be enhanced by making use of the PHA recommendations before final installations are completed. P&IDs are to be completed along with having the operating procedures in place and the operating staff trained to run the process before startup. The initial startup procedures and normal operating procedures need to be fully evaluated as part of the PSSR to assure a safe transfer into the normal operating mode for meeting the process parameters.
For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than "replacement in kind" made to the process during shutdown go through the management of change procedures. P&IDs will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and non-routine work in the process area may need some refresher or additional training in light of the changes. Any incident investigation recommendations, compliance audits or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before beginning the startup.
The PSSR shall confirm that prior to the introduction of highly hazardous chemicals to a process:
- Construction and equipment is in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place and are adequate;
- For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements specified in Management of Change.
The checklist to be completed by the PSSR team includes specifying that:
- The construction and equipment has been checked for conformance with design specifications and applicable codes and standards.
- Applicable process safety information has been developed or updated as necessary to reflect the new/modified process.
- Plant wide safe work procedures are adequate considering the new/modified process conditions.
- Standard operating procedures and emergency procedures have been developed or updated as needed to ensure safe operation of the new/modified process.
- Maintenance procedures and a preventative maintenance schedule have been developed or updated as needed to ensure safe operation of the new/modified process.
- For new processes, the modification has been subjected to management of change review and all recommendations have been resolved or implemented before startup.
- For modified processes, the modification has been subjected to management of change review and all recommendations have been resolve or implemented before startup.
- Training of each employee involved in operating and /or maintaining the process has been completed and documented.
The PSSR is essential to ensuring that the new or modified facilities will perform as envisioned. The larger and more complex the project, the greater is the need to perform a PSSR. Large projects tend to fall behind schedule so that near the end there is usually pressure to cut corners to speed up the schedule. This is also the point in time where the potential for mistakes may be greatly increased. Under these circumstances it is even more important to step back and conduct a thorough PSSR. PTS can provide experienced personnel that understand the need for the PSSR and bring a mature understanding of the pressures the PSSR team members will face.