A pre startup safety review (PSSR) is a structured, documented review conducted before hazardous chemicals are introduced into a new or modified process. It confirms that equipment, procedures, training, and safety systems are installed and functioning as designed.
Under OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119(i)), a pre startup safety review is required for new facilities and for modifications large enough to require updates to process safety information. When executed correctly, a PSSR prevents startup incidents, regulatory exposure, and costly rework.
If your organization operates under PSM, a pre startup safety review is mandatory before startup or restart.
Why a Pre Startup Safety Review is Required
The purpose of a pre startup safety review is direct: confirm that construction matches approved design and that the process is safe to start.
OSHA requires the review to confirm that:
- Construction and equipment meet design specifications
- Safety, operating, maintenance, and emergency procedures are in place
- A Process Hazard Analysis (PHA) has been completed for new facilities and recommendations resolved
- Management of Change (MOC) requirements have been satisfied for modified facilities
- Affected employees have been trained
A PSSR is the final field verification before startup.
When is a Pre Startup Safety Review Required?
A pre startup safety review is typically required in the following situations:
- Startup of a new PSM-covered process
- Restart of a process after a prolonged shutdown
- After a modification that impacts process safety information
The OSHA standard requires a pre startup safety review when a modification is significant enough to require changes to process safety information.
Examples of changes that often trigger a pre startup safety review include:
- New equipment installations
- Modifications to piping or instrumentation
- Changes to control systems or interlocks
- Increases in chemical inventory above threshold quantities
- Fire protection or relief system changes
Organizations that define trigger events clearly within their PSM program experience fewer compliance gaps and fewer rushed startup decisions.
What Does a Pre Startup Safety Review Include?
Most pre startup safety review checklists address the following:
1. Construction and Equipment Verification
- Equipment installed per approved drawings and specifications
- Pressure relief devices properly sized and documented
- Interlocks and alarms tested
- Safety systems operational
2. Process Safety Information (PSI)
- P&IDs updated to reflect as-built conditions
- Relief device calculations available
- Design basis documented
3. Procedures
- Operating procedures completed and approved
- Emergency action plan in place
- Maintenance procedures finalized
4. Training
- Operators trained on startup, normal operations, and emergency response
- Training documentation available
5. Action Item Closure
- PHA recommendations resolved or tracked
- MOC action items closed
- Any startup critical items completed
Standardized PSSR checklists, like those commonly used in industry, help teams verify safety training, PPE, interlocks, relief systems, documentation, and mechanical integrity prior to startup.
The Relationship Between Pre Startup Safety Review and Management of Change (MOC)
MOC evaluates risk before a change is implemented. PSSR confirms the change was installed and prepared correctly before startup. Here’s how it works in many organizations:
- The MOC process determines if a PSSR is required
- The PSSR verifies MOC action items are complete
- Startup authorization follows successful PSSR completion
Think of it this way:
- MOC asks: Did we evaluate the risk of this change?
- PSSR asks: Did we build and prepare it correctly?
Skipping either step is not recommended!
Who Should Participate in a Pre Startup Safety Review?
A PSSR should be conducted by a cross functional team familiar with the process and equipment, for example:
- Operations personnel
- Engineering representatives
- Maintenance supervisors
- Safety or EHS professionals
- Project managers
- Process safety specialists
At least one participant must be knowledgeable in the operation of the process, as required by OSHA guidance. Strong PSSR programs avoid simple “check-and-sign” approvals. Instead, they document the review, list documents examined, capture deficiencies, and track corrective actions.
Common Pre Startup Safety Review Compliance Issues
OSHA inspections frequently identify problems with pre startup safety review execution, such as:
- Conducting the pre startup safety review after chemicals are introduced
- Incomplete documentation
- Outdated P&IDs at the time of review
- Unresolved PHA or MOC action items
- Inadequate training verification
A pre startup safety review must be completed before startup, not after the fact.
Treating the pre startup safety review as a paperwork exercise instead of a field verification step defeats its purpose.
How to Build a Strong Pre Startup Safety Review Program
- Clearly defined trigger events
- Standardized PSSR checklist templates
- Integration with the MOC workflow
- Defined team roles and approval authority
- Action item tracking system
- Periodic auditing of completed PSSRs
Pre Startup Safety Review Services from Safety by Design
A pre startup safety review is one of the most important parts of a Process Safety Management program. Safety by Design supports organizations with PSSR as well as annual health and safety reviews, site safety assessments, safety program development, risk assessment and online OSHA safety training.
If you need help with your pre startup safety review process, get in touch our safety training company.
Contact a safety specialist today to see how we can help!
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