Episode 51 - Pre-Startup Safety Review for Process Safety Management (PSM)

Episode 51 explains the Pre‑Startup Safety Review (PSSR) element of OSHA’s Process Safety Management Standard (29 CFR 1910.119). Dr. Ayers focuses on why PSSRs are essential for ensuring that new or modified processes are safe, ready, and fully compliant before startup.

The core message: A PSSR is the final safety gate. If you start up without it, you’re gambling with lives.

  🧭 Purpose of the PSSR

A PSSR ensures that:

• New or modified equipment is installed correctly

• Safety systems are in place and functional

• Procedures reflect the current process

• Workers are trained and prepared

• All hazards introduced by the change have been evaluated and controlled

It is the final verification step before introducing hazardous chemicals or energy into the system.

  🔄 When a PSSR Is Required

A PSSR must be completed:

• Before startup of new processes

• Before startup after significant modifications

• Whenever an MOC (Management of Change) triggers it

Dr. Ayers emphasizes that PSSR and MOC are tightly linked — if a change affects safety, a PSSR is required before restarting.

  📋 What a PSSR Must Verify

Episode 51 highlights the essential components of a compliant PSSR:

1. Construction and Equipment

• Equipment is installed per design specifications

• Materials of construction are correct

• Safety‑critical equipment is in place and functional

2. Process Safety Information (PSI)

• PSI is complete, accurate, and updated

• Operating limits, chemical hazards, and equipment data are current

3. Operating Procedures

• Procedures reflect the new or modified process

• Startup, shutdown, emergency, and normal operations are documented

4. Training

• Operators and maintenance personnel are trained on:

  • New hazards

  • New procedures

  • New equipment

  • Changes introduced by the MOC

5. Safety Systems

• Alarms, interlocks, relief devices, and shutdown systems are tested

• Safeguards identified in the PHA are in place

  🧪 Common PSSR Failures Highlighted in the Episode

Dr. Ayers calls out typical breakdowns:

• PSSR performed as a paperwork exercise

• Procedures not updated before startup

• Operators not trained on new hazards

• Incomplete PSI

• Safety systems not tested

• Temporary changes bypassing PSSR

• MOC and PSSR not integrated

These failures often lead to startup‑related incidents — some of the most catastrophic in industry history.

  🔗 How PSSR Connects to Other PSM Elements

PSSR is directly tied to:

• MOC — triggers the need for a PSSR

• PSI — must be updated before review

• Operating Procedures — must reflect the change

• Training — must be completed before startup

• PHA — may require revalidation

PSSR is the final checkpoint ensuring all other elements are aligned.

  🧑‍🏫 Leadership Responsibilities

Safety leaders must:

• Ensure PSSRs are completed before startup — no exceptions

• Require thorough, field‑verified reviews

• Confirm PSI, procedures, and training are updated

• Empower reviewers to stop startup if conditions aren’t met

• Treat PSSR as a risk‑control tool, not a compliance form

• Integrate PSSR tightly with MOC and project management

The episode’s core message: A strong PSSR prevents startup disasters. A weak one invites them.