A pre-startup safety review (PSSR) is a crucial part of any process safety management program (PSM), and it is the final step to ensure safety and efficacy before bringing an updated or new process online.
That said, there is often a temptation to rush this process or skip key elements of PSSR due to time constraints or budget pressures, and this has been an ongoing issue in asset-heavy facilities.
Ultimately, proper PSSR actually starts with an effective change process to help increase visibility of the scope and ensure a smooth PSSR. Here, we will discuss common PSSR oversights and how to properly address them with effective change management and document management.
PSSR: The Basics
In the big picture, PSSRs are built to avoid workplace incidents and resultant equipment damage or employee harm – and improperly implemented PSSR can cause major disasters or even death. In 2005, for example, improper PSSR at the BP Texas City refinery led to 170 injuries and 5 deaths, and there are many similar incidents on record.
It is an important process to take seriously and to ensure you get right.
Common PSSR Oversights and OSHA Regulation
The challenge with any person-dependent process is ensuring quality engagements from everyone involved. When time gets tight and work stress elevates, the following deficiencies often arise:
- Failure to conduct a PSSR after process modifications or a prolonged equipment outage.
- Assembling a limited team without the necessary knowledge and skills to adequately perform the complete PSSR.
- Skipping or omitting parts of the PSSR needed to ensure the full scope of the change is reviewed and ready to start.
- Omitting critical safety features from the review or not checking them for proper installation and operation.
- Missing appropriate approval steps for the PSSR before proceeding to start or restart the process.
That is why, in 1992, OSHA implemented the PSM program.
PSSR regulations, specifically, are discussed in OSHA 29 CFR (Code of Federal Regulations) 1910.119(I). These regulations state:
1. 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.
2. The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process:
- Construction and equipment is in accordance with design specifications;
- Safety, operating, maintenance, and emergency procedures are in place and are adequate;
- 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).
- Training of each employee involved in operating a process has been completed.
Why It Matters: The Benefits of Effective PSSR
This OSHA regulation and the rules that it lays out are important. Ultimately, a well-executed PSSR process can help ensure that new or updated processes and assets:
- Are properly designed
- Have adequate and complete safety, operating, emergency, and maintenance procedures
- Have all relevant information available and complete
- Meet the original design and operating intent of the process plant or facility
- Have been properly installed per design specifications
- Have undergone appropriate safety reviews, including HAZOP study, model review, etc.
It can also help ensure that the right procedures and process documentation are in place, that all relevant training has been completed, and that a PHA has been conducted.
How to Get PSSR Right
There are many moving parts to getting PSSR right, and it can be difficult to maintain organization and clarity. More than anything, proper PSSR execution requires effective change management and document management.
1.Ensure Change Management Process is Present
Step one with PSSRs is to ensure the change management process is there.
That means ensuring that the right people are on board and modifying their behavior to adopt the new process you are trying to implement. There are many tools and techniques used to properly guide your people through this process, and it is supremely important. After all, if your employees are not embracing, adopting and utilizing a change then it will not be effective.
To this end, a tool like Accruent’s Meridian engineering document management software can help. With engineering document management software, you can make sure that all relevant documents and elements are housed inside a single tool.
Meridian, specifically, is designed to facilitate these changes and reviews by defining the owners, highlighting the tasks associated, managing the changing documentation, and owning the relationships between these documents and your physical assets. At the same time, Meridian allows the appropriate team members to see the entire process to better ensure a complete scope is considered for all changes.
Additionally, Meridian allows you to:
- Preserve established control of engineering data changes
- Keep master data up-to-date while organizing change processes in dedicated project areas
- Provide highly configurable workflows based on organizational needs
This can help streamline the change management process and ensure that everyone is on the same page at all times.
2. Involve Team Members in Review and Approval Process
Oftentimes, businesses do not have the right people on board to ensure that a PSSR is properly carried out. This is a recipe for PSSR failure, as getting it right requires both qualified employees and a safety-minded, knowledgeable management team.
To correct this, you should assemble a multi-disciplined, comprehensive team to help carry out the PSSR and any follow-up activities. This should include personnel from design and construction, safety, engineering, maintenance, operations, instruments and controls, and supervisors.
You should also include those who need to review and approve the changes, along with relevant documents like anything happening in parallel that would ultimately be classified as an engineering documentation change.
3. Make PSSR Part of Your Ongoing Maintenance and Operations Process
As the PSSR process continues, it ultimately becomes a maintenance and operations process. This makes sense if you think about it: PSSR is a form of preventive action, or action that is taken to avoid a potential negative outcome down the road. But eventually that turns into continuous improvement. There will always be change, and that change must be continuously monitored to ensure safety and efficacy.
This is where a PSSR is a key part of MOC (management of change) which will include cross-functional reviews and approvals. The goal here? To use the information at hand to increase product quality, reduce costs and increase production efficiency.
Again, organizational technology can help here by allowing you to automate each step of your MOC workflow. That way, you can efficiently collect change ideas, formalize the analysis of the ideas, and document the approval and execution of the change.
You can also analyze the current state or the health of your MOC and PSSR processes to ensure ongoing success and create an atmosphere of “no surprises.”
4.Include All Relevant Departments
The traditional PSSR roles are engineering and maintenance, but in today’s heightened environment of oversight and regulations, maintenance and operations cannot successfully operate without including EHNS and compliance organizations.
A properly structured PSSR, then, will include a broad cross-functional team, including:
- A knowledgeable and authoritative supervisor
- Design and construction personnel
- Engineering personnel
- Instrument and controls personnel
- Maintenance personnel
- Operations personnel
- Safety personnel
When it comes to change management and effectively updating or altering your systems, remember that speed is never as important as accuracy. Effective PSSR – facilitated by an engineering document or information management system like Meridian – can help ensure that accuracy so you make safe, effective changes throughout your organization.
What’s more, Meridian can provide easy, auditable proof of a well-executed PSSR so if you get audited by OSHA your business is prepared.
Learn more about the Meridian engineering document management platform.