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Operational Readiness (PSSR)

Pre-startup safety review closing the gap between construction completion and live operation

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Strategic context

What this element is — and why it matters

Operational Readiness — operationalised as the Pre-Startup Safety Review (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 matches design, all PSM elements applicable to the new or modified process are in place, PHA recommendations have been closed (or risk-accepted), and operators have been trained on updated procedures.

Individual significance for organisations

PSSR is the last opportunity to catch the post-modification incident pattern before it manifests in operation. Sites with disciplined PSSR programmes achieve dramatically lower startup-incident rates. Williams Olefins, Tesoro Anacortes, and BP Texas City CSB reports all included PSSR findings — incidents that happened because the formal gate either wasn't 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's ready for operation.

Key requirements

What compliant execution looks like

Pre-startup safety review per OSHA PSM (i)

Construction-vs-design match verification (walk-down)

PHA / HAZOP action close-out signoff

Operating procedure update and operator training

Mechanical integrity, electrical, and instrumentation completion

PSSR signoff by site leadership before introduction of HHC

Implementation methodology

How we implement this element

A focused 6-step methodology calibrated to deliver operational readiness (pssr) as a working capability — not a documented compliance artefact.

PSSR Scope Definition

Define PSSR scope per OSHA PSM (i) — new construction, MOC-driven modification, post-turnaround restart; align with corporate PSSR procedure.

Walk-Down Protocol

Multi-discipline walk-down — process, mechanical, electrical, instrumentation, HSE; verify construction matches P&ID; document deviations and resolution.

PHA Action Close-Out

Confirm all PHA / HAZOP / LOPA / SIL actions related to the change are closed or risk-accepted with documented evidence; align with PHA register.

Procedure & Training

Verify operating procedures updated to reflect change; operator training complete with documented competency; emergency response procedure aligned.

MI / SIS / HAC Verification

Mechanical integrity sign-off (relief sized, vessel coded), SIS commissioned (FAT / SAT), HAC drawings issued, ESD / F&G commissioned.

Leadership Signoff

Site leader and HSE manager signoff before chemicals introduced; specify authorisation hierarchy and audit trail.

Implementation flow

Element-implementation flow chart

Decision-gated workflow showing the actual sequence of activities — from initiation through steady-state operation — with key decision points highlighted.

Start

MOC implementation complete; PSSR triggered

Multi-Discipline Walk-Down

Process / mechanical / electrical / instrumentation / HSE

Decision

Construction Matches Design?

Decision gate

PHA Action Close-Out Check

All PHA / HAZOP / LOPA / SIL actions closed or risk-accepted

Procedure Currency Check

Operating procedures updated per change

Operator Training Verification

Role-relevant training complete + competency demonstrated

MI Sign-Off

Relief sizing, vessel codes, RBI plan in place

SIS Commissioning

FAT / SAT complete; cause-and-effect verified

HAC + ESD + F&G Verification

Hazardous area + emergency systems commissioned

Decision

Leadership Signoff?

Decision gate

HHC Introduction Authorised

Startup proceeds with full audit trail

Deliverables

What we produce

PSSR scope and procedure
Multi-discipline walk-down protocol and checklist
PHA action close-out verification record
Procedure / training verification register
MI / SIS / HAC commissioning signoff
Leadership signoff authorisation record

Common pitfalls

Where execution fails

PSSR done as checklist without field walk-down depth
PHA actions still open at PSSR — risk-accepted without justification
Operator training certified but not field-verified
Leadership signoff delegated without informed decision

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 — and integrate it with the other Risk Based Process Safety (RBPS) elements you already operate.

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