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The term Pre-startup 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
pre-startup safety reviews.
The wording of the two standards regarding PSSRs is virtually identical, although the
industries covered and the reporting requirements differ slightly.
The fundamental purpose of a pre-startup 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.
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 pre-startup 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 were in place and that they were followed. Nor is a PSSR a last-minute hazards
analysis.
The PSSR team will typically check that a hazard 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.
A Pre Startup Safety Review covers not only equipment, but also procedures and training.
Pre Startup Safety Review procedure/guideline is normally prepared as part of Pre-
commissioning/ commissioning documentation.
To ensure that installation meets the original design and operating intent of process
plant/facility
To ensure safety, operating, maintenance and emergency procedures are in place and
adequate
To ensure appropriate safety reviews during engineering phase (HAZOP study, model
review etc.) have been carried out and all action items have been completed
To ensure any site modifications during construction phase have been properly
controlled and noted
To ensure training of each employee involved in the operating process is completed
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.
Following activities are carried out in a PSSR with coordination between Contractor and
Owner of the plant / facilities:
2. Documentation Review:
The documentation review is to check the availability and status of operating manuals, start-
up/shutdown and emergency procedures. Following documents should be checked for
availability and status:
Operating manuals/procedures
Emergency procedures
Instruction of handling of chemicals
Operation checklists on safety equipment
Safeguarding Memorandum
As-built P&IDs/PFDs
Area Classification drawings, Plot Plans
Fire Protection drawings
It could be carried out when the construction is nearing mechanical completion (about 90-95
% completion) and the site is reasonably accessible. The site review will concentrate on such
issues as:
The PSSR checklists shall be completed by each discipline. A sample of operation checklist is given in
following table: