October 6, 2024
OSHA's Process Safety Management (PSM) Pre-Startup Safety Review (PSSR) is a critical step before starting up new equipment. Here are the top 5 reasons why it's so crucial, along with insights on how it can be applied to non-PSM regulated operations:
1. Ensures Safety and Prevents Incidents
The PSSR is designed to prevent workplace incidents, equipment damage, and employee harm[4]. By thoroughly reviewing all aspects of a new or modified process before startup, potential hazards can be identified and addressed proactively, significantly reducing the risk of accidents.
2. Verifies Compliance with Design Specifications
A key function of the PSSR is to confirm that construction and equipment are in accordance with design specifications[3]. This ensures that the actual implementation matches the intended design, reducing the likelihood of unexpected issues during operation.
3. Validates Safety Procedures and Training
The review confirms that safety, operating, maintenance, and emergency procedures are in place and adequate[3]. It also verifies that all necessary employee training has been completed, ensuring that personnel are prepared to operate the new equipment safely.
4. Implements Process Hazard Analysis Recommendations
For new facilities, the PSSR ensures that a process hazard analysis has been performed and its recommendations have been resolved or implemented[3]. This step is crucial for identifying and mitigating potential risks associated with the new process.
5. Facilitates Continuous Improvement
The PSSR process ultimately becomes part of a continuous improvement cycle, allowing for ongoing monitoring and enhancement of safety and efficiency[4]. It helps create an atmosphere of "no surprises" by thoroughly evaluating changes before implementation.
While PSSR is mandated for PSM-covered processes, its principles can be valuable for any operation introducing new equipment or processes:
1. Risk Mitigation: The systematic approach of PSSR can help any organization identify and address potential safety hazards before they lead to incidents.
2. Quality Assurance: By verifying that new equipment meets design specifications, non-regulated operations can ensure product quality and operational efficiency.
3. Employee Preparedness: The training verification aspect of PSSR can be applied to ensure all staff are adequately prepared to operate new equipment safely and effectively.
4. Change Management: The PSSR process aligns with good change management practices, which are beneficial for any organization implementing new processes or equipment[4].
5. Documentation and Compliance: Even for non-regulated operations, maintaining thorough documentation of safety reviews can be valuable for internal audits, insurance purposes, and demonstrating due diligence.
By adopting PSSR principles, organizations outside of PSM regulation can enhance their safety culture, improve operational efficiency, and reduce the risk of costly incidents or downtime associated with new equipment startups.
Citations:
[1] https://www.osha.gov/process-safety-management
[2] https://www.wolterskluwer.com/en/expert-insights/process-safety-management-what-you-need-to-know
[3] https://en.wikipedia.org/wiki/Process_Safety_Management_(OSHA_regulation)
[4] https://www.accruent.com/resources/blog-posts/pre-startup-safety-review-pssr-what-you-need-know
[5] https://www.osha.gov/sites/default/files/publications/osha3132.pdf
[6] https://www.osha.gov/sites/default/files/enforcement/directives/CPL_02-01-065.pdf
[7] https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.119
[8] https://www.osha.gov/process-safety-management/sbrefa