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Risk Based Process Safety (RBPS)Manage Risk

Operational Readiness (PSSR)

A pre startup safety review that closes the gap between construction completion and live operation

Strategic context

What this element is and why it matters

Operational Readiness, operationalised as the Pre Startup Safety Review or PSSR, is the final structured check before highly hazardous chemicals are introduced into the process. The element maps to OSHA 1910.119(i) and verifies that construction and installation match the design, that every PSM element applicable to the new or modified process is in place, that PHA recommendations have been closed or formally risk accepted, and that operators have been trained on the updated procedures. Our team runs this gate so the last check before startup carries real weight.

Operational Readiness (PSSR)

Individual significance for organisations

PSSR is the last opportunity to catch the post modification incident pattern before it shows up in operation. Sites with disciplined PSSR programmes achieve dramatically lower startup incident rates. The CSB reports for Williams Olefins, Tesoro Anacortes, and BP Texas City all included PSSR findings, incidents that happened because the formal gate was either never held or held without substance.

Contribution to Risk Based Process Safety (RBPS)

PSSR is the closing gate for MOC (Element 13) and the opening gate for live Operating Procedures (Element 8) and Conduct of Operations (Element 15). It verifies Asset Integrity (Element 10) commissioning, Training (Element 12) completion, PHA action closure (Element 7), and procedure currency (Element 8). PSSR is the integration point where the entire management system proves it is ready for operation.

Key requirements

What compliant execution looks like

A pre startup safety review per OSHA PSM (i)
Verification through a walk down that construction matches design
PHA and HAZOP action close out signoff
Operating procedure updates and operator training
Completion of mechanical integrity, electrical, and instrumentation work
PSSR signoff by site leadership before highly hazardous chemicals are introduced
Implementation methodology

How we implement this element

A focused six step methodology calibrated to deliver operational readiness (pssr) as a working capability rather than a documented compliance artefact.

PSSR Scope Definition

We define the PSSR scope per OSHA PSM (i) across new construction, MOC driven modification, and post turnaround restart, aligned with your corporate PSSR procedure.

Walk Down Protocol

We run a multi discipline walk down across process, mechanical, electrical, instrumentation, and HSE, verify that construction matches the P&ID, and document deviations and their resolution.

PHA Action Close Out

We confirm that every PHA, HAZOP, LOPA, and SIL action related to the change is closed or risk accepted with documented evidence, aligned with the PHA register.

Procedure and Training

We verify that operating procedures are updated to reflect the change, that operator training is complete with documented competency, and that the emergency response procedure is aligned.

Integrity, Instrumented System, and Area Classification Verification

We confirm mechanical integrity signoff with relief sized and vessels coded, the safety instrumented system commissioned through factory and site acceptance testing, hazardous area classification drawings issued, and the emergency shutdown and fire and gas systems commissioned.

Leadership Signoff

We obtain site leader and HSE manager signoff before chemicals are introduced, and specify the authorisation hierarchy and audit trail.

Implementation flow

Element implementation flow chart

A decision gated workflow that shows the actual sequence of activities from initiation through steady state operation, with key decision points highlighted.

Start
MOC implementation is complete and the PSSR is triggered
Multi Discipline Walk Down
Process, mechanical, electrical, instrumentation, and HSE
Decision
Construction matches design?
Decision gate
PHA Action Close Out Check
Every PHA, HAZOP, LOPA, and SIL action closed or risk accepted
Procedure Currency Check
Operating procedures updated for the change
Operator Training Verification
Role relevant training complete and competency demonstrated
Mechanical Integrity Signoff
Relief sizing, vessel codes, and a risk based inspection plan in place
Safety Instrumented System Commissioning
Factory and site acceptance testing complete with cause and effect verified
Area Classification and Emergency System Verification
Hazardous area and emergency systems commissioned
Decision
Leadership signoff?
Decision gate
Chemical Introduction Authorised
Startup proceeds with a full audit trail
Deliverables

What we produce

  • A PSSR scope and procedure
  • A multi discipline walk down protocol and checklist
  • A PHA action close out verification record
  • A procedure and training verification register
  • A mechanical integrity, instrumented system, and area classification commissioning signoff
  • A leadership signoff authorisation record
Common pitfalls

Where execution fails

  • A PSSR run as a checklist without the depth of a real field walk down
  • PHA actions still open at PSSR and risk accepted without justification
  • Operator training certified on paper but never field verified
  • Leadership signoff delegated without an informed decision behind it
Standards & references

Codes this element is built on

OSHA 29 CFR 1910.119(i) (Pre Startup Safety Review, US)CCPS Guidelines for Operational ReadinessCCPS Guidelines for Performing Effective Pre Startup Safety ReviewsMSIHC Rules 1989 Rule 4 (India)Factories Act 1948 §41B (India)OISD STD 128 (PSSR India)
Implement this element

Talk to us about implementing Operational Readiness (PSSR)

We can scope this element implementation against your facility, regulatory context, and existing management system maturity, then integrate it with the other Risk Based Process Safety (RBPS) elements you already operate.