Notice I used the word “necessary” and not the word required. In my experience, a PSSR saved my ass plenty of times when OSHA/EPA did NOT require it. To my knowledge, OSHA (nor EPA) have defined the word “facilities” in the context they used it in 1910.119(i)(1)… (emphasis by me)
| 1910.119(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. |
So I pose the question… Is a PSSR “necessary” for a Replacement in Kind (RIK)?
My answer is – under certain situations, it ABSOLUTELY is! Here is one of those situations.