Pre-startup Safety Review (PSSR): Ian Sutton
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| Pre-startup Safety Review (PSSR) - 4th Edition |
Plus "A change, plus c'est la meme chose". Alphonse Karr (1808 - 1890) |
| 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 following changes to the process or the way in which the process is operated. The wording of the two standards regarding PSSRs is virtually identical. However, the industries that they cover and their respective 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 and that the process/facility is not required to operate in an unsafe condition. A PSSR aims to catch any changes that may have crept into the system during the detailed engineering and construction phases of a project. A 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 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 are in place, and that they are followed. Nor is a PSSR a last-minute hazards analysis. The PSSR team should check that a hazards 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. |
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The OSHA PSM Regulation
Because of its role in creating the concept of pre-startup safety reviews in the process industries, the OSHA process safety management (PSM) regulation to do with the topic is discussed in this section.
Regulation and Guidance
The OSHA standard to do with pre-startup Safety Reviews is to be found in paragraph (i) of the regulation. The regulation itself is shown in Table 1; OSHA's guidance on the topic is provided in Table 2.
Table 1
OSHA PSM Regulation
The employer shall perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information.
The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process:
(i) Construction and equipment is in accordance with design specifications;
(ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate;
(iii) 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 contained in management of change, paragraph (l) [ of this regulation ].
Table 2
OSHA PSM Guidance
For new processes, the employer will find a PHA 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 pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters.
For existing processes that have been shut down 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 the 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.
Discussion of the Regulation
The first paragraph of the regulation states that a PSSR is needed whenever Process Safety Information (PSI) is changed. In effect, this requirement is such that virtually all changes will have to be reviewed in a PSSR. There are very few changes that do not require some information changes to do with topics such as safe limits, engineering drawings, and equipment lists.
(i) Construction and Equipment
Paragraph (i) of the standard requires that construction and equipment is in accordance with design specifications. PSSR team members can carry out spot-checks of the installed piping and equipment, and compare it with the piping lists and equipment datasheets.
(ii) Procedures
Paragraph (ii) requires that the facility's procedures reflect the manner in which the facility is to be operated after the process changes have been made. The PSSR should check that safety, operating and emergency procedures for the new operation have been written down, and that they accurately describe what has to be done. This paragraph does not mention training, but it can be assumed that operators and maintenance workers must be trained in the use of the new procedures.
(iii) New / Modified Facilities
The regulation requires that new facilities conduct a process hazards analysis (PHA). The PSSR team should check that the PHA was in fact carried out and that its recommendations were either resolved or implemented. During the pressure of construction, there is sometimes a tendency to postpone some of the PHA recommendations until 'there is sufficient time'. The PSSR should check that the recommendations have, in fact, been closed out properly.
Additional information to do with the topic of hazards analysis is provided in the ebook Process Risk Management, details of which can be found at https://bin95.com/ebooks/risk-tree-analysis.htm .
Management of Change and Audits
The way in which PSSRs, MOCs, and audits link to one another is demonstrated in Figure 1.
Figure 1
PSSR / MOC / Audit
The process in Figure 1 can be illustrated using the standard worked example, first introduced in PSSR,MOC,Audits: Worked Examples.
Table of Contents
Introduction
The OSHA PSM Regulation
Regulation and Guidance
Discussion of the Regulation
(i) Construction And Equipment
(ii) Procedures
(iii) New / Modified Facilities
Management of Change and Audits
Change Process
Audits
Scope of a PSSR
Organization of a PSSR
Restart Safety Reviews
Conclusions
Index
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