Pre Startup Safety Review (PSSR) OSHA PSM 1910.119(i)
We verify that design, construction and the supporting safety systems are ready before highly hazardous chemicals enter the process
Pre Startup Safety Review
(PSSR) OSHA PSM 1910.119(i)
OSHA PSM 1910.119(i) is the final gate before highly hazardous chemicals enter a new or a modified process, and our team runs it as a genuine check rather than a signature on the way out the door. The element asks you to confirm that construction and equipment match the design specifications under (i)(2)(i), that the safety, operating, maintenance and emergency procedures are in place under (i)(2)(ii), that the recommendations from your process hazard analysis have been resolved or implemented under (i)(2)(iii), and that operator training is complete under (i)(2)(iv). It is the practical expression of CCPS RBPS Element 14 on operational readiness. Williams Olefins, Tesoro Anacortes and BP Texas City all carried pre startup review findings in their CSB reports, incidents that happened because the formal gate was either skipped or held without real substance. We make sure your gate has substance.
How the study is executed
A structured, facilitated process that runs from scope definition through close out and produces defensible, actionable outputs.
Per (i)(1), trigger PSSR for new construction or MOC driven modification before HHC introduction, align with corporate PSSR procedure.
Multi discipline walk down, process, mechanical, electrical, instrumentation, HSE, verify construction matches P&ID, document deviation resolution.
Per (i)(2)(iii), confirm PHA / HAZOP / LOPA / SIL actions closed or risk accepted with documented evidence.
Per (i)(2)(ii) and (iv), confirm operating procedures updated and operator training complete with documented competency.
Mechanical integrity, SIS commissioning (FAT / SAT), HAC drawings, ESD / F&G commissioning, align with relevant codes.
Site leader and HSE manager signoff before HHC introduction, specify authorisation hierarchy and audit trail.
What the study covers in full
Outcomes of Pre Startup Safety Review (PSSR) OSHA PSM 1910.119(i)
- Catches the incident pattern that so often follows a modification
- Confirms that hazard analysis actions are closed before live operation
- Confirms that operator training and procedures are current
- Provides a real final gate before any highly hazardous chemical is introduced
- A documented record that defends your position under OSHA 1910.119(i)
- Coverage that maps to CCPS RBPS Element 14
- Alignment with the CCPS operational readiness guidelines
- Conformance with the procedural requirements of Factories Act Section 41B
- A lower rate of startup errors
- A cleaner handover to the operating crew
- Stronger close out of hazard analysis actions
- Genuine integration across every engineering discipline
- Avoidance of post startup incident cost
- Less commissioning rework
- A defensible record your insurer can rely on
- A faster path to steady state operation
Codes & standards we work to
Triggers that signal the need
Where Pre Startup Safety Review (PSSR) OSHA PSM 1910.119(i) applies
Wellheads, separators, gas compression, FPSO topsides, produced water systems.
Distillation columns, reactors, heat exchangers, storage spheres, LPG handling.
Cryogenic exchangers, liquefaction trains, BOG compressors, storage and sendout.
Reactive systems, batch reactors, solvent handling, runaway reaction scenarios.
Boilers, HRSGs, steam headers, hydrogen systems, ammonia SCR units.
Sterile vessels, CIP/SIP, pressure fermenters, solvent recovery, spray dryers.
Tangible deliverables
- A pre startup review procedure with a defined trigger and scope
- A multi discipline walk down checklist
- A verification record showing hazard analysis actions closed out
- A procedure and training verification register
- A mechanical integrity, instrumented safety and hazardous area commissioning signoff
- A leadership signoff and authorisation record
Ready to start your project?
Speak with our team to scope an engagement tailored to your facility, regulatory context, and lifecycle stage.