Pre-startup safety review (PSSR)

Introduction to Pre-startup Safety Review (PSSR)

In industries dealing with hazardous chemicals or intricate equipment setups, ensuring operational safety before launching new or altered processes is crucial. This is where the Pre-startup Safety Review (PSSR) comes into play. PSSR is a systematic assessment conducted before igniting equipment, systems, or processes that have undergone maintenance or substantial changes, including new installations or prolonged inactivity. It’s essential, especially in sectors like oil and gas, chemical manufacturing, energy production, and pharmaceuticals.

Regulatory standards, such as those set by OSHA under 29 CFR 1910.199(I), mandate PSSR to manage risks linked with Management of Change (MOC) processes and identify hazards through techniques like Hazard and Operability Study (HAZOP), ensuring compliance with health, safety, and environmental (HSE) standards.

Why PSSR is Mandatory

Yes, PSSR is mandatory. Its primary goal is to confirm all safety measures are in place before commencing or restarting processes, crucial in hazardous industries to prevent accidents and protect both employees and the environment.

Key Regulatory Bodies and Standards Include:

• OSHA: Requires PSSR for processes involving highly hazardous chemicals.
• API: Offers industry-specific guidelines for the oil and gas sectors.
• ISO: ISO 45001 outlines occupational health and safety systems compatible with PSSR.
• EPA: Monitors environmental safety, emphasizing the necessity of PSSR for complying with environmental standards.

PSSR’s Key Objectives

The main objective of a PSSR is to confirm that new or modified equipment installations meet safety standards and operational protocols before activation. Objectives include ensuring:

• Systems are designed, installed, and functioning correctly.
• Hazards are identified and mitigated.
• Workers are adequately trained for safe equipment operation and maintenance.

Training and Execution of PSSR

For effective PSSRs, personnel involved must be trained on the protocols, hazard identification techniques like HAZOP, principles of MOC, and emergency response procedures related to OSHA and industry-specific regulations.

Team Composition and Roles

A successful PSSR requires a diverse team, typically composed of:

• Process Engineers: Evaluate system operation according to design specifications.
• Maintenance Personnel: Ensure equipment installation and maintenance are up to standard.
• HSE Professionals: Identify potential risks and ensure health and environmental standards.
• Operations Personnel: Provide operational insights for everyday safety.
• MOC Coordinator: Document and review all process changes for approval.

PSSR Execution Process

The PSSR process includes several structured steps outlined below:

1. Pre-planning and Team Formation: Identify relevant systems and gather a multidisciplinary team.
2. Review the PSSR Checklist: Ensure all design, equipment, and safety elements are covered.
3. Site Inspection: Visit the facility to verify installations and safety system functionality.
4. Documentation and Procedure Review: Confirm procedures, MOC reviews, and regulatory documents are accurate.
5. Operational Tests: Conduct tests to ensure functionality under normal and emergency conditions.
6. Identification and Resolution of Action Items: Address any deficiencies and ensure all issues are resolved.
7. Team Sign-off and Close Out: Final review and documentation of completed action items.
8. Documentation and Record Keeping: Store all records per OSHA guidelines for future audits.

Conclusion

PSSR is pivotal for ensuring safety and operation integrity in industrial settings. It’s not merely a recommendation but a regulatory necessity for maintaining a safe working environment.