Pre-Startup Safety Review (PSSR): Key Insights from Our Recent Webinar
Pre-Startup Safety Review (PSSR) is an essential step in safeguarding the safety and efficiency of operations during facility startups. The goal of a PSSR is to identify potential hazards and operational issues before they become significant challenges. By conducting a thorough PSSR, companies can minimize risks and facilitate smoother startup processes.
In our recent webinar on Pre-Startup Safety Review (PSSR) , we explored the PSSR process in detail, highlighting its importance in preventing safety incidents and promoting operational success. We also addressed common questions and concerns related to PSSR implementation. Below, we’ve summarized key insights and provided practical answers to some of the questions raised during the session.
What are common gaps identified during a Pre-Startup Safety Review (PSSR) that would otherwise go unnoticed?
A Pre-Startup Safety Review (PSSR) is designed to identify issues that may be missed during normal operations or reviews. Some of the common gaps identified during a PSSR include:
- BPCS/SIS Interlocks Not Working as Expected: These interlocks play an important role in system safety. A PSSR verifies they function correctly before startup.
- Missed Safety Equipment in the PHA: Equipment such as flame arrestors, which are necessary for safe operations, might be missed in the PHA, but a PSSR can identify the gap.
- Unaddressed PHA Recommendations: Sometimes, recommendations from the PHA are not followed through. A PSSR helps confirm these recommendations are implemented before startup.
- Incomplete Standard Operating Procedures (SOPs): SOPs are key to safe operations. Missing or incomplete SOPs can result in problems during startup.
- Lack of Operator/Mechanic Training: If operators and mechanics haven’t been properly trained on the new system, it can lead to mistakes. A PSSR makes sure training is complete before startup.
How do you balance the need for a thorough review with time-sensitive operational deadlines?
Although a thorough Pre-Startup Safety Review (PSSR) is important, it must also be completed within the constraints of operational timelines. Here are strategies to manage both:
- Preliminary PSSR Tasks During Project Phases: Many tasks within the Pre-Startup Safety Review (PSSR) can be started earlier in the project so they don’t delay the final review phase.
- Unit-Specific PSSR: For large projects, conducting a PSSR in smaller, unit-specific phases allows for more manageable timelines and reduces pressure on the overall schedule.
How do you handle scenarios where a PSSR uncovers deficiencies late in the startup timeline?
When deficiencies are identified late in the startup process, it’s important to resolve them promptly:
- Communicate to Upper Management: Any significant issues discovered late in the timeline should be communicated to upper management along with their severity and risk. Possible solutions and timelines for resolution should also be included.
- Temporary Mitigation Measures: If the unit must start up before deficiencies are addressed, temporary safety measures should be put in place. A Temporary Management of Change (MOC) should be signed off by the Plant Manager, PSM Engineer, and Operator to ensure safe operations during this period.
What are the most effective risk mitigation strategies identified through a PSSR, and how are they prioritized?
The most effective risk mitigation strategies identified through a Pre-Startup Safety Review (PSSR) typically stem from the HAZOP phase of the project. These strategies include:
- Engineering Controls: Implementing physical safeguards like pressure relief valves, flame arrestors, or emergency shutdown systems.
- Procedural and Administrative Controls: Establishing clear procedures, such as permit-to-work systems, safety checklists, and emergency response plans.
- Mechanical Integrity: Ensuring equipment is regularly inspected, maintained, and replaced as needed to prevent failures.
- Training and Competency: Providing targeted training and competency assessments for workers to handle specific hazards effectively.
- Personal Protective Equipment (PPE): Requiring appropriate PPE, such as chemical-resistant gloves, flame-resistant clothing, or respiratory protection, to mitigate residual risks.
Strategies identified during a HAZOP should be prioritized as follows:
- By Risk Level: Address strategies targeting the highest-risk scenarios first.
- By Severity: If multiple risks have the same risk level, prioritize those with the most severe consequences.
- By Consequence Type: If severity is the same, prioritize based on the type of consequence in this order:
- Safety concerns: Mitigate risks that could harm personnel first.
- Safety concerns: Mitigate risks that could harm personnel first.
- Environmental impact: Next, address risks with potential harm to the environment.
- Environmental impact: Next, address risks with potential harm to the environment.
- Financial concerns: Lastly, focus on risks that could cause financial losses.
Can you share examples of systemic improvements made as a result of lessons learned from a PSSR?
A Pre-Startup Safety Review (PSSR) can lead to systemic improvements, particularly in the areas of project planning and safety:
- Improved Scheduling: Allocating more time for the PSSR process based on the size and complexity of the project guarantees there’s no rush during the review.
- Complete Process Safety Information (PSI): Confirming that all necessary PSI is available and complete for review helps avoid delays and incomplete assessments.
- Interlock Confirmation and Testing: Verifying that BPCS and SIS interlocks function as expected before startup guarantees operational safety.
- Ensuring that PHA Recommendations are in place: Ensuring all PHA recommendations are addressed before startup helps avoid issues during operation and delays in commissioning.
What tools or resources help address all sections of a PSSR effectively?
Effective Pre-Startup Safety Review (PSSR) processes rely on structured tools such as checklists, templates, and procedural frameworks to thoroughly cover every aspect of the review. These tools help verify compliance with regulatory requirements, identify potential hazards, and document findings systematically. Organizations, such as Sigma-HSE, tailor these resources to each review’s specific processes and risks to ensure relevance and effectiveness.
How would PS and PSSR pertain to Geothermal facilities and projects managed?
In general, the Process Safety (PS) and Pre-Startup Safety Review (PSSR) processes would follow the same structure as with other types of facilities. However, the key differences lie in the specific hazards and risks associated with geothermal operations. These may include challenges related to high-temperature systems, geothermal fluid handling, and unique environmental considerations. As a result, the PSSR process would need to be adapted to address these particular risks and ensure safe operations throughout the facility’s startup and ongoing operation.
Do you need to redo a PSSR as RAGAGEP changes based on new engineering literature?
If Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) change over time, the Pre-Startup Safety Review (PSSR) or HAZOP might need to be revalidated. This is especially true if the change in standards affects any identified hazards. A Management of Change (MOC) should be implemented in such cases. Additionally, OSHA requires HAZOP revalidations every five years to ensure continued compliance with Process Safety Management (PSM) standards, for operations covered under 1910.119.
These answers highlight how a PSSR can help identify gaps, mitigate risks, and enhance safety during facility startups. For more information or to explore how Sigma-HSE can support your PSSR process, feel free to reach out. Our team is ready to partner with you in achieving your process safety goals.
By applying the best practices from this webinar, you can enhance safety and optimize the efficiency of your facility’s startup process.
You can watch the webinar on demand Webinar: Pre-Startup Safety Review (PSSR) – Ensuring Safe Operations Before You Begin
