Pre Start Up Safety Review (PSSR)

What Is a Pre-Start-Up Safety Review (PSSR)

Definition and Scope of PSSR

A PSSR is a structured safety check conducted before starting up a new or modified industrial process. It ensures all equipment, procedures, and systems meet design and safety standards.

Objectives of Conducting PSSR

• Verify that construction and equipment match the intended design.
• Ensure all operating and emergency procedures are ready and effective.
• Confirm staff training is complete and hazards are managed.
• Confirms that all systems are properly designed, installed, tested, and operating as intended.
• Identifies potential hazards associated with new or modified processes and ensures appropriate risk controls are in place.
• Verifies that personnel are adequately trained and competent to safely operate and maintain the equipment.

Regulatory and Industry Context

PSSR is required under OSHA’s Process Safety Management (PSM) regulations and recommended by industry safety guidelines. It helps maintain compliance and demonstrates commitment to process safety.

Is PSSR mandatory?

Yes, PSSR is mandatory in several regulated industries, especially those handling hazardous chemicals or processes.

• OSHA: Required under Process Safety Management (29 CFR 1910.119) before startup of new or modified processes
• API (American Petroleum Institute): Recommends PSSR as a key process safety element for safe startup
• ISO Standards: Support PSSR through management of change and operational control requirements
• EPA: Aligns PSSR with Risk Management Plan (RMP) regulations to prevent chemical incidents
  PSSR ensures regulatory compliance and safe operational readiness.

What are the common PSSR oversights and OSHA regulations?

Common PSSR oversights can lead to regulatory noncompliance and safety incidents.

• Incomplete hazard analysis or unresolved action items

• Missing or outdated operating and emergency procedures

• Inadequate training of operators and maintenance personnel

• Safety systems not tested or improperly commissioned

• Poor documentation of management of change

OSHA regulations require verification that all safety, equipment, and procedural elements are in place before startup.

Why PSSR Matters: Importance and Benefits

Preventing Incidents During Start-Up

Start-up phases are high-risk periods. PSSR identifies hidden hazards, helping to prevent leaks, fires, and equipment failures.

Verifying Engineering and Design Conformance

It confirms that equipment, systems, and modifications match the original design intent, avoiding operational surprises.

Ensuring Operational Readiness

PSSR validates that procedures, safety systems, and staff are prepared to operate the process safely.

Supporting Compliance and Risk Management

It ensures regulatory compliance, strengthens risk management practices, and provides documentation for audits and inspections.

When and Where to Perform a PSSR

Triggers for PSSR (New vs Modified Units)

PSSR should be performed for:

• New facilities before introducing hazardous materials.
• Modified processes whenever changes impact process safety or design.

Timing in Project and Commissioning Phases

It should be done after construction and pre-commissioning, just before start-up, so issues can be corrected in time.

Roles and Participants in a PSSR Team

A multidisciplinary team typically includes operations, engineering, maintenance, and safety personnel. Independent reviewers can help reduce bias.
Core Elements of the PSSR Process

Documentation Review Requirements

• Check engineering drawings, specifications, and process diagrams.
• Ensure operating, maintenance, and emergency procedures are complete and accessible.
• Confirm all safety permits and approvals are obtained.

Physical Walk-Through and System Verification

• Inspect equipment, safety devices, and control systems on-site.
• Verify alarms, shutdown systems, and interlocks are functional.
• Ensure labeling and signage are correct and visible.

PHA Action Item Verification

• Check that all Process Hazard Analysis recommendations are addressed.
• Ensure corrective actions are closed or properly mitigated.
• Confirm risk control measures remain effective.

Training and Competency Confirmation

• Verify that all staff have received proper training.
• Ensure operators understand hazards, operating limits, and emergency procedures.
• Conduct drills or simulations if required.

Management of Change (MoC) Compliance Check

• Confirm all design or process changes went through a formal change management process.
• Verify that safety, health, and environmental impacts of changes are assessed.
• Ensure all documentation from changes is integrated into procedures and training.

How to Conduct a Pre-Startup Safety Review (PSSR)

A Pre-Startup Safety Review (PSSR) should follow a structured, documented process to ensure safe and compliant startup.

Define the PSSR Scope

Identify new, modified, or relocated equipment, processes, and systems requiring review.

Form a Cross-Functional Team

Include representatives from engineering, operations, maintenance, safety, and management.

Verify Design and Construction

Confirm equipment installation matches approved design specifications and safety requirements.

Review Hazard Analysis

Ensure process hazard analysis recommendations are completed or properly managed.

Inspect Safety Systems

Test alarms, interlocks, relief devices, emergency shutdowns, and control systems.

Validate Procedures

Confirm operating, maintenance, and emergency procedures are accurate and accessible.

Confirm Training Readiness

Verify that operators and maintenance personnel are trained and competent.

Close PSSR Action Items

Resolve all critical findings before granting final startup approval.

Best Practices for Effective PSSR Implementation

Use of Standardized Checklists

• Use a clear, structured checklist tailored to your facility.
• Include regulatory and safety requirements.
• Update checklists regularly based on lessons learned.

Clear Sign-Off and Approval Workflow

• Define roles, responsibilities, and approval authorities.
• Record all action items and their resolution.
• Issue “Ready for Startup” certification only when all critical items are closed.

Continuous Improvement and Feedback Loop

• Review the effectiveness of PSSR after start-up.
• Collect feedback from operations and safety teams to improve future reviews.
• Update procedures based on real-world learnings and incidents.

Leadership and Cross-Functional Collaboration

• Engage senior leadership to secure resources and commitment.
• Foster collaboration between operations, maintenance, safety, engineering, and quality teams.
• Empower staff to halt start-up if unresolved safety issues are identified.

Documentation and Reporting in PSSR

Structure of a PSSR Report

• Include objectives, scope, team members, and reviewed processes.
• Summarize findings from document review, walk-throughs, and verification.
• List action items with status and priority.

Tracking and Resolving Punch-List Items

• Assign clear ownership and deadlines for each item.
• Track progress until full resolution.

Final Approval and Start-Up Clearance

• Issue “Ready for Startup” only after all critical items are closed.
• Obtain formal sign-off from operations, safety, engineering, and management.

Monitoring Open Items Post-Start-Up

• Track non-critical items that remain open at start-up.
• Verify completion during initial operations or subsequent audits.

Read More: Ways to Improve Construction Site Safety

Challenges and Common PSSR Pitfalls

Bias in Internal Reviews

Internal teams may overlook issues due to familiarity or assumptions. Independent reviewers reduce this risk.

Schedule- or Budget-Driven Shortcuts

Pressure to meet deadlines can lead to skipped steps. Rushing a PSSR compromises safety.

Incomplete Closure of Recommendations

Unresolved action items from hazard analyses may leave hidden risks. Ensure all items are verified.

Poor Documentation and Follow-Up

Incomplete or missing documentation reduces accountability and can hide unresolved hazards.

Conclusion

A Pre-Start-Up Safety Review (PSSR) is a vital step to ensure a facility operates safely and efficiently. By systematically checking equipment, procedures, and personnel readiness, it prevents incidents, strengthens compliance, and improves operational confidence. For expert PSSR support and HSE management solutions, contact Aura Safety Risk Consultant. We help you maintain safety, compliance, and sustainable industrial growth.