Pre-startup Safety Review (PSSR)

Major changes, then, such as revamping an industrial facility, reverting to its original process afterwards, or restarting it after a shutdown need to be managed well to minimize process safety risks. Major changes, then, such as revamping an industrial facility, reverting to its original process afterwards, or restarting it after a shutdown need to be managed well to minimize process safety risks.
Objectives
The objective of carrying out PSSR is to
⦁ Define the key attributes for a PSSR in the oil, gas, and petrochemical industry.
⦁ Use the the attributes demonstrated to support and define risk
⦁ Recommend improvement to clients to improve their management systems
When to do a PSSR
Within the plant modification process
The PSSR “event” typically sits after construction completion and before the introduction of hazardous substances. Normally it is associated with “handover” from the construction organization to plant operations. However, Larger capital projects will require several PSSRs. For example a PSSR before commissioning (“RFC – readiness for commissioning”), between commissioning and start-up (“RFISU – readiness for initial start-up”) and between start-up and full hand over (“RFSU – readiness for start-up”).

Circumstances where a PSSR is appropriate
A PSSR is broadly beneficial where any change modifies the process safety information1. It is recommended that a PSSR be carried out prior to the commissioning or re-start step in the following circumstances:
⦁ Capital projects.
⦁ Modified equipment.
⦁ New valves or valve operation.
⦁ A new type of reactor or process vessel.
⦁ Start-up after a turnaround (even if no modifications are involved).
⦁ Other changes involving a change in process safety information per the OSHA definition
Who carries out the PSSR?
PSSR Leader
The head of the operations section who will be managing the plant in future is generally recommended as the most appropriate PSSR leader. An alternative approach is that the project engineer is the leader.
Assigning a PSSR team
This is a multi-disciplinary team comprising of:
⦁ Engineer responsible for the design of the project.
⦁ Representative of the operations department which will take over the facility.
⦁ Representative of the maintenance department.
⦁ Coordinator of the process.
⦁ Requestor of the change or project facilitator or his designee.
⦁ Optional participants, by title, depending on type of project and organizational structure
What are the key steps in a PSSR?
An organization should develop a written PSSR procedure requiring the following steps:
⦁ Identification of the need for a PSSR, sometimes referred to as the trigger event
⦁ Assignment of a PSSR leader and team
⦁ The PSSR team meeting to discuss the purpose of the PSSR, and review all the items on the PSSR checklist
⦁ Team sign-off for one of the following scenarios:
⦁ Facility is ready to start-up or move to next phase.
⦁ Facility may be started-up but there are some issues which need to be dealt with after start-up. These issues will be listed in the PSSR checklist, with responsibilities.
⦁ Facility may not be started up until some issues are dealt with. These issues will be listed in the PSSR checklist with responsibilities.
⦁ A managerial sign-off that the plant is ready to start-up or move to next phase. The manager may or may not be part of the PSSR team, but the input from the PSSR team will be his/ her primary source of advice that the facility is not ready to start-up.
⦁ Action tracking with regards to issues which need to be dealt with after the PSSR. For organizations with central action tracking systems, this central action tracking system should also be used for the PSSR actions.
The PSSR form checklist
The PSSR checklist used will depend on the nature of the site’s processes and hazards.
Key items in a checklist will include, but not limited to:
⦁ All completions such as mechanical completion and punch lists have been completed and signed off.
⦁ A punch list for items for completion before or for consideration for completion after start-up.
⦁ Completion of operator training.
⦁ Standard operating procedures have been revised if required.
⦁ Emergency operating procedures have been revised if required.
⦁ Commissioning procedure for first start-up including consideration of withdrawal of nonessential personnel, and additional personnel to be available, staffing of adjacent areas.
⦁ Process hazards analysis including HAZOPs available, and requisite actions taken on the recommendations made in the PHA.
⦁ Any regulatory issues such as flaring notified to the regulator accordingly.
⦁ PPE requirement defined, understood and available.
Recommendations
It is recommended that the checklist items consist of items which it is reasonable for the PSSR team to verify. The PSSR team can check that there are pressure relief valve design calculations, and they can check that there has been a process hazards analysis, and that all the recommendations have been addressed.