Pre Startup Safety Review (PSSR)
The verification before highly hazardous chemicals are introduced that confirms design, construction, and PSM readiness
What this element is and why it matters
OSHA PSM at 1910.119(i) is the final gate before highly hazardous chemicals are introduced into a new or modified process. The element requires verification that construction and equipment match the design under (i)(2)(i), that procedures are in place under (i)(2)(ii), that hazard analysis recommendations are resolved under (i)(2)(iii), and that training is completed under (i)(2)(iv). Our team runs this gate with the depth it deserves so nothing goes live untested.
Individual significance for organisations
This review is the last opportunity to catch the post modification incident pattern before it shows up in operation. The CSB reports on Williams Olefins, Tesoro Anacortes, and BP Texas City all included findings on this review, incidents that happened because the formal gate was either never held or held without any real substance. Facilities with a disciplined review programme have dramatically lower startup incident rates, and that is exactly what we help your team achieve.
Contribution to OSHA Process Safety Management (29 CFR 1910.119)
Paragraph (i) is the closing gate for management of change in (l) and the opening gate for live operating procedures in (f). It pulls together verification of the process safety information in (d), closure of the hazard analysis in (e), completion of training in (g), and commissioning of mechanical integrity in (j) into a single readiness sign off. This is where the whole management system proves it is ready for operation, because without this gate modifications go live untested.
What compliant execution looks like
How we implement this element
A focused six step methodology calibrated to deliver pre startup safety review (pssr) as a working capability rather than a documented compliance artefact.
To meet (i)(1) we trigger the review for new construction or any change driven modification before a highly hazardous chemical is introduced and align it with your corporate review procedure.
We run a multidisciplinary walk down across process, mechanical, electrical, instrumentation, and HSE, verify that construction matches the P&ID, and document how each deviation is resolved.
To meet (i)(2)(iii) we confirm that all HAZOP, LOPA, and SIL actions are closed or formally risk accepted with documented evidence.
To meet (i)(2)(ii) and (iv) we confirm that operating procedures are updated and that operator training is complete with documented competency.
We verify mechanical integrity, safety instrumented system commissioning through factory and site acceptance testing, area classification drawings, and shutdown and fire and gas commissioning against the relevant codes.
We require the site leader and HSE manager to sign off before any highly hazardous chemical is introduced and define the authorisation hierarchy and the record trail.
Element implementation flow chart
We run pre startup safety review (pssr) as a gated sequence rather than a checklist. Where the work reaches a gate it goes forward or back on what the step before it found, and it is the gates that decide whether the element holds.
What we produce
- A review procedure with its trigger and scope
- A multidisciplinary walk down checklist
- A record verifying close out of hazard analysis actions
- A register verifying procedures and training
- An integrity and safety system commissioning sign off
- A leadership sign off authorisation record
Where execution fails
- The review done as a checklist without the depth of a real field walk down
- Hazard analysis actions risk accepted without proper justification
- Training certified on paper but never verified in the field
- Leadership sign off delegated without an informed decision
Codes this element is built on
Explore related elements in this framework
OSHA Process Safety Management (29 CFR 1910.119) full element index
Talk to us about implementing Pre Startup Safety Review (PSSR)
We will come back with the gap against the standard, the work it would take to close it and how it lands against the elements around it. Tell us the site and which OSHA Process Safety Management (29 CFR 1910.119)elements you already operate.