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Keep the cost of achieving and maintaining PSM
affordable by calling us today. Winter is typically
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Pre-Startup
Review )
 | What the regulation says:
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(i)(1) The
employer shall perform a pre-startup safety
review for new facilities and for modified
facilities when the modification is significant
enough to require a change in the process safety
information.
(i)(2) The
pre-startup safety review shall confirm that
prior to the introduction of highly hazardous
chemicals to a process:
(i)(2)(i) Construction
and equipment is in accordance with design
specifications;
(i)(2)(ii) Safety,
operating, maintenance, and emergency procedures
are in place and are adequate;
(i)(2)(iii) For
new facilities, a process hazard analysis has
been performed and recommendations have been
resolved or implemented before startup; and
modified facilities meet the requirements
contained in management of change, paragraph
(l).
(i)(2)(iv) Training
of each employee involved in operating a process
has been completed.
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| What it means:
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new processes, the employer will find a PHA helpful in
improving the design and construction of the process
from a reliability and quality point of view. The safe
operation of the new process will be enhanced by making
use of the PHA recommendations before final
installations are completed. P&ID’s are to be
completed along with having the operating procedures in
place and the operating staff trained to run the process
before startup. The initial startup procedures and
normal operating procedures need to be fully evaluated
as part of the pre-startup review to assure a safe
transfer into the normal operating mode for meeting the
process parameters.
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| For
existing processes that have been shutdown for
turnaround, or modification, etc., the employer must
assure that any changes other than "replacement in
kind" made to the process during shutdown go
through the management of change procedures.
P&ID’s will need to be updated as necessary, as
well as operating procedures and instructions. If the
changes made to the process during shutdown are
significant and impact the training program, then
operating personnel as well as employees engaged in
routine and non-routine work in the process area may
need some refresher or additional training in light of
the changes. Any incident investigation recommendations,
compliance audits or PHA recommendations need to be
reviewed as well to see what impacts they may have on
the process before the introduction of ammonia to the
new or modified process.
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PSMCI Newsletter
Compliance news and issues.
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