Most engineers in the chemical process industry talk about management of change (MOC) with authority, but you rarely hear them mention pre-startup safety review (PSSR) in the same breath. It seems all of the elements of process safety management (PSM) are important for discussion but one: PSSR. Why? I am not sure, but it is the final check (review) that might just save your skin someday. That's why it is part of the OSHA PSM standard and EPA Risk Management Plan (RMP) Rule.
PSSR is one of the 14 elements of the OSHA standard. PSSR was, and is, as important as any of the elements of PSM/RMP/BSSE. It is designed to give you pause and ensure a thoughtful analysis of whether you're ready to push the "Go" button.
There are two facets to PSSR. First, PSSR is a redundant check that a change has been reviewed, analyzed, approved and accomplished in a quality manner. A "quality manner" means the change has been accomplished, usually by maintenance staff, in a manner acceptable by operations and in alignment with the design and operating intent of the facility. The change must be complete and well done before it is accepted by operations.
PSSR is designed to give you pause and ensure a thoughtful analysis of whether you're ready to push the "Go" button.
Second, a PSSR is intended to be a check that all process safety information has been updated and all the training concerning the change has been completed. This is no trivial matter. Two-thirds of all incidents are caused by human error. Human reliability is heavily influenced by procedures and the associated training, so we do not want to forget that. Next, and just as important, is the process safety information needs to be kept up to date. This is important for two reasons. Information such as process and instrumentation diagrams (P&IDs) are used for decision making all the time. If P&IDs are inaccurate, bad decisions can result. Also, P&IDs are the basis for unit-wise process hazard analysis. If they are incorrect, hazards can be missed.
Beyond that, PSSR can be used when no MOC or change has occurred. After a turnaround or shutdown, a PSSR is required. Companies also use PSSR when bringing a unit out of moth balls. We might call this check something else such as a readiness review or punch list, but these are still PSSRs. I think most people see PSSR as a redundant, unnecessary step. That is flat out wrong. MOC and PSSR are not the same process, and they may not even be connected or joined in a workflow.
PSSRs are required for all change that requires a change to process safety information (procedures, hazards of the process, technology, equipment, safe operating limits, etc.). That covers about every change there is and a few more. Why do we talk so much about MOC and not PSSR?
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