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.
I have to replace a valve or a pump. The work is 100% a RIK in every respect. But I was raised that every time the primary containment boundary is compromised/broken, we do a PSSR to ensure the work to remove and install the RIK item was done in a manner in which the process is ready to receive the HHC/EHS.
We view the PSSR as a tool, not a document that has to be filled out to satisfy OSHA/EPA. Using this tool can be a great aid in ensuring our adopted RAGAGEP builds back our primary containment correctly. Whether the joinment to the valve or pump is welded or flanged, putting it all back together is CRITICAL, and the PSSR is the tool we use to manage this critical aspect of process safety.
Some want to say all we have to do is meet OSHA minimum expectations; however, I have been blessed in my career to work for businesses that wanted more than what compliance offered, and when I started consulting, I was blessed that many of those I worked with became clients and the love for doing process safety the right way continues. We also learned from our incidents, and as I stated earlier, I had several incidents associated with RIK work when the process was NOT put back together per our RAGAGEPs. Each time our excuse was that the PSSR was not “required” for the RIK work. But in each of these events, our causal analysis always led us back to needing something that would help us ensure the process is ready to receive the HHC/EHS after the RIK is completed, and each time we ended up with the PSSR being that tool.
It boils down to this…
If the RIK valve or pump is in place via welds, we must ensure those welds are inspected, pressure tested, and leak tested!
If the RIK valve or pump is in place via flanges, we must ensure the flanges’ proper torquing, tightening patterns, pressure testing, and leak testing!
It is not the change that poses the risk, it is the breaking of our primary containment barrier that creates the risk. We have to put the process back together the same way it was built BEFORE we re-introduce the HHC/EHS to the area where this RIK work took place.