Pre-Startup Safety Review (PSSR)
What is a PSSR?
A PSSR is an audit or review that should be completed before the startup of a new or modified process system or equipment. It should be documented, structured, and conducted by personnel who are independent of the project team.
A PSSR provides a documented review of new or modified equipment, systems, and facilities to confirm:
a) Adequate safety, operating, and maintenance procedures are in place. b) New facilities have been designed and constructed with adequate engineering controls.
c) Hazardous processes have been appropriately controlled.
d) The quality risk management process has been followed to ensure there are no significant hazards associated with the intended operation.
e) Changes have been adequately assessed for their potential impact on safety and quality, and risks have been appropriately managed accordingly.
What is considered a startup?
A startup is a procedure on a piece of equipment to change the operational status of that equipment from a non-operational state to an operational state, typically from an inactive state (idle) or standby state to an active state.
Startups are normally performed after shutdowns as part of the start-up procedure. Startups may also be performed as part of routine maintenance activities, including troubleshooting and repair activities.
Startups can be classified by the purpose of the startup: preventative maintenance startups, corrective maintenance startups, and system startups. Preventative maintenance startups are performed before reaching a scheduled shutdown point, such as before a weekend.
Corrective maintenance startups are performed to correct an observed malfunction in equipment performance or to correct a condition that has arisen during shutdown activities.
System startups consist of all other types of startups. This includes both preventative and corrective maintenance startups, as well as those performed due to unscheduled equipment outages.
Types of PSSR
There are three types of PSSR: simple, complex, and urgent.
Simple PSSR can be used for minor changes in process equipment (e.g., installation or replacement).
Complex PSSR is used for more significant modifications in process equipment or installation of new systems.
Urgent PSSR is done as part of an urgent MOC.
What does the PSSR requirements look like?
Cal/OSHA states, in 8 CCR Section 5194.1(a)(2), that “A covered employer shall develop, implement and maintain a written process safety management program designed to prevent or mitigate hazards associated with hazardous chemicals used by the employer”.
EPA/CalARP states, in 40 CFR Part 68.110(a), states that “Each owner or operator subject to this subpart shall develop and implement a risk management program that is designed to prevent or minimize catastrophic releases of regulated substances.”
HSE requires that “The organization must have in place a documented, formal process safety management system to be applied throughout the organization which will ensure that process safety risks are properly identified and controlled” per HSE Policy No. 2 – HSE Risk Management Program.
The common element among all three programs is Process Safety Management; thus, PSSR is required for each program.
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