Most PSSR forms we encounter simply regurgitate OSHA’s 1910.119(i)(2). If the user is thoroughly knowledgeable of what each of these four (4) line items entails, we may be able to execute the PSSR appropriately. Let’s look at these four line items, especially the first line.
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1910.119(i)(2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: 1910.119(i)(2)(i) Construction and equipment is in accordance with design specifications 1910.119(i)(2)(i) Construction and equipment is in accordance with design specifications; 1910.119(i)(2)(ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate; 1910.119(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). 1910.119(i)(2)(iv) Training of each employee involved in operating a process has been completed. |
This single line item, (i)(2)(i), INCLUDES a ton of responsibility, as well as documents/data, to embrace what it is attempting to achieve fully. This line item covers EVERYTHING (physical object) the HHC/EHS touches; however, I will discuss only how it impacts PSM/RMP piping in this article.
We see a lot of PSSR in our travels, and almost all of them will have this line item signed off as completed; however, when we ask for piping installation records, we get the “deer in the headlights” look. Here is what a facility should have to sign off on this single PSSR line item properly: