Environment, Health, and Safety (EHS) managers working in high-risk industries should be very familiar with pre-startup safety reviews (PSSR). PSSR is one of the 14 elements of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard and is also included in its counterpart, the Environmental Protection Agency’s (EPA) Risk Management Program (RMP).
PSSR is a crucial final step before a plant-wide or process-specific startup (or a restart following a shutdown, maintenance, or a change in operations or equipment). The review process involves structured steps such as documentation review, on-site inspections, and PSSR team coordination to ensure safety and compliance.
Despite its importance, PSSR is often overshadowed by other PSM elements. While it may feel like a redundant safety step, essentially a double-check. it serves as a critical step in the where the PSSR process begins.
Double-checking can seem inefficient, especially when it’s the final hurdle in an already lengthy process, but doing PSSR correctly can be the difference between a smooth startup and a potentially catastrophic failure.
Fortunately, there’s a simple tool EHS professional can use to balance the swift efficiency their organization demands with the accurate attention to safety it requires: checklists.
Here we’ll explore how PSSR relies on a well designed checklist and offer tips to help you create one that suits your organization’s needs. A well-structured PSSR process helps ensure regulatory requirements are met and operational readiness is achieved.
A successful PSSR requires careful planning, clear roles, and thorough documentation to achieve safety and compliance goals.
What Is PSSR, and Why Are Checklists Essential?
PSSR is defined within the PSM and RMP standards, specifically under 29 CFR 1910.119(i))) and 40 CFR 68.77. Employers are required to perform PSSR for new facilities or after a facility is modified in a way that requires any change in process safety.
According to the regulations (the language is the same under both), a PSSR must confirm the following before introducing highly hazardous chemicals into a process:
- Construction and equipment are in accordance with design specifications.
- All necessary safety and emergency procedures are in place and adequate.
- New facilities have completed process hazard analyses (PHA) and implemented any necessary corrections/updates, and modified facilities have met all management of change requirements.
- Every employee involved in the process must complete relevant training to ensure understanding of safety protocols and responsibilities.
The PSSR team, often a cross-functional review team, is responsible for verifying that all key components, such as new or modified equipment and new or modified processes, meet regulatory compliance and safety standards.
This will mean different things for different organizations. Although these standards are mandated only if the facility uses select hazardous chemicals in excess of defined thresholds, PSSR’s precautionary review can enhance safety in diverse industries from oil and gas to manufacturing—basically any operation that involves the manufacturing or use of hazardous chemicals.
Regardless of the specific industry, checklists help EHS managers define and standardize the necessary safety protocols. This standardization helps ensure:
- Compliance with regulatory standards,
- Accuracy of process so that no critical steps are overlooked,
- Proper communication among team members, and
- Accountability and proper documentation throughout.
Conducting hazard analysis and process hazard analysis is essential to identify potential hazards and ensure proper documentation is maintained for continuous safety improvement.
While it may sound tedious, the stakes are high. To cite just one example, it was determined that a 2005 BP refinery explosion occurred due to insufficient PSSR during a restart. The incident left 15 workers dead and 180 injured.
When discussing compliance, it is important to meet regulatory requirements set by regulatory bodies and maintain thorough documentation for audit readiness.
For modified facilities, reviewing modified processes and new or modified process equipment is critical to ensure all identified risks are addressed and that safety measures are updated accordingly.
Building Your PSSR Checklist
While you will need to customize your PSSR checklists to fit the needs of your organization, they must generally include five critical elements:
- Equipment inspections that ensure correct installation and operational safety, including complex equipment, control systems, safety interlocks, and emergency shutdown systems.
- Documentation reviews to verify that all process safety information (PSI), operating procedures, PSSR documentation, and maintenance procedures are complete and up to date.
- Tests of safety systems that confirm all safety controls, alarms, and shutdown systems are functional.
- Verification of training to ensure all relevant personnel have completed required courses and have demonstrated knowledge and competency in operating procedures.
- Management of change (MOC) to review any changes to equipment and/or processes and verify that safety protocol has been updated and communicated accordingly.
To tailor these checklist elements to their specific industry or facility, EHS leaders must take the following steps:
- Identify key risks and hazards associated with the specific startup process.
- Consult regulatory and industry guidelines to ensure the checklist serves to meet all compliance obligations and incorporates industry best practices.
- Involve a cross functional team or multidisciplinary team, including maintenance personnel, to ensure the checklist covers all critical variables. These teams may include engineering, operations, management, and front-line supervisors and employees.
- Review emergency response plans to ensure emergency systems and emergency response procedures are verified and up to date.
- Use digital tools to efficiently create and update checklists, simplify documentation and tracking, manage PSSR protocols, streamline PSSR processes, and ensure proper sign off and continuous improvement.
A step by step guide for conducting a PSSR should include on site inspection and site inspection as critical steps to ensure all aspects of safety and compliance are addressed.
PSSR Checklist Benefits: Avoid Pitfalls, Continuously Improve
Like all organization process safety and emergency procedures, the PSSR process relies on humans—and humans are notoriously imperfect. This is one of the biggest benefits of pre startup safety review checklists: they serve as a bulwark against common pitfalls in the process, many of which are due to human error. Some of these pitfalls (and how checklists prevent them) include:
- Overlooked equipment issues. A comprehensive checklist will cover every variable to consider during PSSR in the requisite level of detail, reducing the risk that something will be forgotten when relying on memory alone.
- Missing documentation. A checklist helps EHS managers quickly confirm all the appropriate documentation is in place—and shows where corrective action is needed. A checklist is also its own form of documentation, serving to improve accountability. Using software solutions specially designed to create, complete, and track checklists further reduces the likelihood of document loss or mismanagement.
- General resistance to change. Humans are simply inclined to resist change in many situations, and this resistance can take the form of complacency—a huge pitfall for PSSR. The clarity provided by checklists helps overcome the sense of uncertainty or ambiguity that may contribute to a fear of change.
- Unaddressed risks and safety concerns. PSSR checklists help ensure all known risks and potential safety concerns are addressed before startup, reducing the likelihood of incidents.
A PSSR checklist is also essential for accident prevention and minimizing the risk of safety systems failing, as well as reducing significant safety incidents from occurring. The PSSR process and specifically, PSSR checklist, does this by ensuring all critical steps in the PSSR process are followed and hazards are systematically reviewed.
Beyond simple avoidance of pitfalls, checklists also provide the opportunity for continuous safety improvement. As with your other safety initiatives, be sure to gather feedback from employees regarding PSSR—and use that feedback to refine and improve your checklists over time. Regularly updating safety measures is crucial to address new risks and maintain high safety standards.
Safety? Check. Efficiency? Check.
By emphasizing a methodical, accurate, and unambiguous step-by-step process to pre startup safety review and the PSSR process, checklists are key to a thorough and compliant PSSR.
In turn, a well-executed PSSR reduces overall risk and promotes safe operations, not only within mandatory standards like PSM and RMP but also the larger context of best management practices.
The important caveat to this, however, is that PSSR checklists must be properly constructed, which means they must be carefully crafted during initial implementation and then regularly updated as necessary.
Configurable EHS software solutions can simplify and streamline some of this work for EHS professionals. Start your free trial of Dakota Inspections to start creating your own checklists—and find ways to further empower both safety and efficiency at your organization.
