The term Prestartup Safety Review (PSSR) first received prominence in the process industries with the introduction of the Process Safety Management (PSM) regulations.
2. Introduction:
•
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 prestart up safety reviews.
• The wording of the two standards regarding PSSRs is virtually identical,
although the industries covered and the reporting requirements differ slightly.
• The basic fundamental purpose of a prestart up 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.
• The PSSR aims to catch any changes that may have crept into to the system
during the detailed engineering and construction phases of a project. PSSR
covers not only equipment, but also soft issues, such as operating procedures
and training.
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3. • PSSRs play an important role in large projects because such projects all too
often fall behind schedule and/or run over budget, thus creating pressure
on the whole 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 lead to 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
prestart up 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 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 were in place and that they were
followed. Nor is a PSSR a last-minute hazards analysis.
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4.
5. What is Pre Startup Safety Review (PSSR)?
• The PSSR is a safety review conducted prior to startup or commissioning of
new modified processing/manufacturing plant or facility so as to ensure that
the new installations meet the original design to catch any potential hazard
due to changes during the engineering and construction phase of the
project.
• In other words it ensures the ready for startup status of a process unit.
• It not only covers the equipment but also the procedures and trainings. It is
basically a part of pre commissioning documentation.
6. What is the purpose of Pre Startup Safety Review?
• To ensure safety, operating, maintenance and emergency procedures are in
place and adequate in the process.
• To ensure appropriate safety reviews during engineering phase (HAZOP study,
model review etc.) have been carried out and all action items have been
completed efficiently.
• To ensure any site modifications during construction phase have been
properly controlled and noted down.
• To ensure that training of each of the employees involved in the operating
process is completed on time.
• In addition, the pre startup safety review plays an important role in large
projects as it may give plant operators the authority to refuse or accept
responsibility for a plant or equipment that they judge to be unsafe through
the PSSR. This is very crucial point and effects the whole organization in great
way.
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7. Main activities in PSSR of a project are defined below:
• Following activities are carried out in a PSSR with coordination
between Contractor and Owner of the plant:
• Coordinate PSSR participation from knowledgeable and experienced
Contractor and Owner personnel.
• Conduct Technical and HSE reviews of documentation and on site.
• Verify that all construction and equipment is in accordance with
safety, environmental and health regulation and standards.
• Complete all corrective action items raised in the PSSR.
• Complete Post- Start-up corrective action items.
• Representative of the Project Owner sign the PSSR checklists
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8. Scope of PSSR:
• This document summarizes how General Manager, Operation complies
with the pre-startup safety review requirements that are needed. Pre-
startup safety reviews are required for all new facilities and for all
facility modifications that result in a change to the process safety
information.
•
•
• There is a sheet below which determines or confirms if the PSSR is
needed or not in a specific case.
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9.
10. The diagram below tells us about the documentation is
needed for PSSR or not:
11. Procedures for Conducting a Pre-Startup Safety
Review:
The steps involved in conducting a pre-startup safety review are:
Initiate the Pre-Startup Safety Review
Conduct the Pre-Startup Safety Review
Authorize the Addition of a Chemical
Complete Follow-Up Activities
1. Initiate the Pre-Startup Safety Review:
For starting a Pre Startup Safety survey, there are mainly two main events which cause it:
Construction of a new facility. A new facility would consist of a facility constructed on a
worksite where there are no other facilities or a facility subsequently constructed such that it
is physically separates from and otherwise independent from existing facilities.
Modify an existing facility where the modifications are significant enough to require a
change in the process safety information. The modifications would be connected to or
otherwise dependent on an existing facility Documentation should be established to verify
completion of this activity.
12. • Ensure that all safety, operating, maintenance and emergency action and
response procedures are written, implemented, and are adequate.
Recognized standards or codes, manufacturers’ instructions, and other
applicable regulations may be considered in drafting procedures.
• Ensure that construction and equipment is in accordance with the design
specifications. The construction codes and standards used should be
documented in the process safety information. Ensure that training for
each employee involved in handling hazardous chemicals has been
completed. The modifications or additions reflected in the pre-startup
safety review may create a need for additional training in other areas such
as maintenance, emergency action and response, or hazard
communication.
• Ensure that the changes or revisions to the PSM documentation (e.g. process
safety information, process hazard analysis, and material handling policies) are
made available to facility employees.
• Ensure that any startup of new equipment is conducted in accordance with
applicable industry standards, manufacturers’ recommendations, or plant
procedures.
13. 2. Conduct the Pre-Startup Safety Review:
New Facilities - For a new facility the following actions should be
taken:
Compile the process safety information including information
concerning the hazards of hazardous chemicals. The process
safety information should be compiled before the process hazard
analysis is performed.
Perform a process hazard analysis that complies with the
requirements of this PSM Program. Refer to the Process Hazard
Analysis section for more details
Resolve or implement all recommendations from the process hazard
analysis prior to startup.
14. Modified Facilities - For modifications to an existing facility the following actions s be taken:
• Ensure that all process safety information is updated.
• Ensure that the requirements for a Management of Change have been completed. A safety
and health review must be performed for a modified facility; the review may involve the
completion of a formal Process Hazard Analysis (PHA) study PSM of a safety review checklist,
depending on the significance of the modification. Refer to the Management of Change
section of the PSM.
• Ensure that the relevant safety, operating, maintenance and emergency evacuation
procedures are in place, have been changed to reflect the modifications or additions if
necessary, and are adequate. All procedures should follow, where applicable, recognized
standards and/or codes, manufacturers’ instructions, and other applicable regulations.
• Ensure that construction and equipment is in accordance with the design specifications. The
construction codes and standards used should be documented in the process safety
information.
• Ensure that training for each employee involved in handling the hazardous chemicals has
been completed including a review of any changes to relevant procedures. The modifications
reflected in the pre-startup safety review may create a need for additional training in other
areas such as maintenance, emergency response, or hazard communication.
15. • Ensure that the changes or revisions to the PSM documentation (e.g. process safety
information, process hazard analysis, and material handling policies) are made available to
facility employees.
• Ensure that any startup of new equipment is conducted in accordance with applicable
industry standards, manufacturers’ recommendations, or facility procedures.
16. Documenting the Pre-Startup Safety Review:
The Pre-Startup Safety Review Verification Form
should be handed to the individuals responsible for
each of the listed requirements. Signatures and dates
should be gathered on the form after satisfactory
completion of the listed requirement such as updating
all written process safety information, conducting a
process hazard analysis, and completing the
requirements of the management of change
procedures.
The pre-start up safety review involves employees
with expertise in chemical inventory and storage
requirement. The employees are selected based upon
their experience and understanding of the process
systems being evaluated.
17. The following personnel are typically involved in verifying the requirements on the Pre-Startup
Safety Review Verification Form:
• Director of management
• General Manager, Operations
• Director Customer Service & Compliance
• Warehouse Coordinator acceptance of the pre-startup safety review requirements.
The last step of the process is to authorize startup of the process by signing and dating the
approval lines on the Pre-Startup Safety Review Verification Form. Once these approval
signatures and dates have been gathered on the form, modifications to the new equipment or
facility can be made successfully.
3. Authorization of the Startup of the Process:
The Pre-Startup Safety Review Verification Form provides a sign-off
18. 4) Complete Follow-Up Activities:
Occasionally, some action items may not be completed before the startup of the
modified system. The follow-up section of the Pre-Startup Safety Review Verification
Form should be used to document the resolution of any open items that were not
completed before the system startup.
Each open item should be documented in this table along with a due date, the
completion date and an explanation describing why the item was not completed
prior to startup.
The individuals who are authorized to approve the startup (i.e. those who sign the
Verification Form) should ensure that the modified system is safe to startup even
though these items have not been completed, i.e. the follow up items should have
no impact on system safety.
19.
20. Below is the image of what a Pre Startup Safety Review
(PSSR) verification form looks like
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