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Dakota Software's Blog for EHS and Sustainability Professionals

Pre-Startup Safety Reviews (PSSR) Made Simple: Creating Checklists That Work

November 14th, 2024 by Dakota Software Staff

Pre-Startup Safety Reviews (PSSR) Made Simple: Creating Checklists That Work

Environment, Health, and Safety (EHS) managers working in high-risk industries should be very familiar with pre-startup safety reviews (PSSR). PSSR is one of the 14 elements of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard and is also included in its counterpart, the Environmental Protection Agency’s (EPA) Risk Management Program (RMP). PSSR is a crucial final step before a plantwide or process-specific startup (or a restart following a shutdown, maintenance, or a change in operations or equipment).

Despite its importance, PSSR is often overshadowed by other PSM elements. While it may feel like a redundant safety step—essentially a double-check—it serves as a vital operational safeguard. Double-checking can seem inefficient, especially when it’s the final hurdle in an already lengthy process, but doing PSSR correctly can be the difference between a smooth startup and a potentially catastrophic failure.

Fortunately, there’s a simple tool EHS professional can use to balance the swift efficiency their organization demands with the accurate attention to safety it requires: checklists. Here we’ll explore how PSSR relies on a well designed checklist and offer tips to help you create one that suits your organization’s needs.

What Is PSSR, and Why Are Checklists Essential?

PSSR is defined within the PSM and RMP standards, specifically under 29 CFR 1910.119(i) and 40 CFR 68.77. Employers are required to perform PSSR for new facilities or after a facility is modified in a way that requires any change in process safety. According to the regulations (the language is the same under both), a PSSR must confirm the following before introducing highly hazardous chemicals into a process:

  • Construction and equipment are in accordance with design specifications.

  • All necessary safety and emergency procedures are in place and adequate.

  • New facilities have completed process hazard analyses (PHA) and implemented any necessary corrections/updates, and modified facilities have met all management of change requirements.

  • Employees involved in the process have completed all necessary training.

This will mean different things for different organizations. Although these standards are mandated only if the facility uses select hazardous chemicals in excess of defined thresholds, PSSR's precautionary review can enhance safety in diverse industries from oil and gas to manufacturing—basically any operation that involves the manufacturing or use of hazardous chemicals. Regardless of the specific industry, checklists help EHS managers define and standardize the necessary safety protocols. This standardization helps ensure:

  • Compliance with regulatory standards,

  • Accuracy of process so that no critical steps are overlooked,

  • Proper communication among team members, and

  • Accountability and documentation throughout.

While it may sound tedious, the stakes are high. To cite just one example, it was determined that a 2005 BP refinery explosion occurred due to insufficient PSSR during a restart. The incident left 15 workers dead and 180 injured.

Building Your PSSR Checklist

While you will need to customize your PSSR checklists to fit the needs of your organization, they must generally include five critical elements:

  • Equipment inspections that ensure correct installation and operational safety.

  • Documentation reviews to verify that all process safety information (PSI), operating procedures, and emergency response plans are complete and up to date.

  • Tests of safety systems that confirm all safety controls, alarms, and shutdown systems are functional.

  • Verification of training to ensure all relevant personnel have completed required courses and have demonstrated knowledge and competency in operating procedures.

  • Management of change (MOC) to review any changes to equipment and/or processes and verify that safety protocol has been updated and communicated accordingly.

To tailor these checklist elements to their specific industry or facility, EHS leaders must take the following steps:

  • Identify key risks and hazards associated with the specific startup process.

  • Consult regulatory and industry guidelines to ensure the checklist serves to meet all compliance obligations and incorporates industry best practices.

  • Involve cross-functional teams to ensure the checklist covers all critical variables. These teams may include engineering, operations, management, and front-line supervisors and employees.

  • Use digital tools to efficiently create and update checklists and simplify documentation and tracking.

Checklist Benefits: Avoid Pitfalls, Continuously Improve

Like any other organizational process, PSSR relies on humans—and humans are notoriously imperfect. This is one of the biggest benefits of checklists to PSSR: they serve as a bulwark against common pitfalls in the process, many of which are due to human error. Some of these pitfalls (and how checklists prevent them) include:

  • Overlooked equipment issues. A comprehensive checklist will cover every variable to consider during PSSR in the requisite level of detail, reducing the risk that something will be forgotten when relying on memory alone.

  • Missing documentation. A checklist helps EHS managers quickly confirm all the appropriate documentation is in place—and shows where corrective action is needed. A checklist is also its own form of documentation, serving to improve accountability. Using software solutions specially designed to create, complete, and track checklists further reduces the likelihood of document loss or mismanagement.

  • General resistance to change. Humans are simply inclined to resist change in many situations, and this resistance can take the form of complacency—a huge pitfall for PSSR. The clarity provided by checklists helps overcome the sense of uncertainty or ambiguity that may contribute to a fear of change.

Beyond simple avoidance of pitfalls, checklists also provide the opportunity for continuous safety improvement. As with your other safety initiatives, be sure to gather feedback from employees regarding PSSR—and use that feedback to refine and improve your checklists over time.

Safety? Check. Efficiency? Check.

By emphasizing a methodical, accurate, and unambiguous step-by-step process, checklists are key to a thorough and compliant PSSR. In turn, a well-executed PSSR reduces overall risk and promotes safe operations, not only within mandatory standards like PSM and RMP but also the larger context of best management practices. The important caveat to this, however, is that PSSR checklists must be properly constructed, which means they must be carefully crafted during initial implementation and then regularly updated as necessary.

Configurable software solutions can simplify and streamline some of this work for EHS professionals. Start your free trial of Dakota Inspections to start creating your own checklists—and find ways to further empower both safety and efficiency at your organization.

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