I am not sure where or quite when this vicious rumor began, but let’s make this clear:
A Pre-startup Safety Review (PSSR) is an ENTIRELY separate exercise AND MUST be completed BEFORE the Initial Start-Up procedures are implemented.
Granted it may be the same personnel doing both tasks, but the PSSR is FULLY COMPLETED BEFORE the Initial Start-Up procedure begins. In fact, the PSSR MUST very that there is even an Initial Start-up Procedure AND that personnel who will be performing the Initial Start-up have been trained and this training has been validated in some way.
The PSSR is NEVER to be done on a “system” within a Process as personnel are implementing the process’es Initial Start-up. Know that when a PSSR is completed that ALL functional safety systems will have been FUNCTIONALLY TESTED and verified to be operational. This means ANY and ALL safety systems and alarm conditions that are NOT satisfied due to the process being empty should be ACTIVATED (e.g. low level/pressure alarms should be sounding and interlocks should be tripped) as these devices do NOT kow we are in Initial Start-up, they just know their parameters have not been met so they are doing what they have been designed to do. Personnel involved in the Initial Start-up MUST understand this and we do this by providing them a…. guess?… An Initial Start-up procedure.
Earlier this month a plant outside of the USA was starting up a new Chlorine process. The facility thought this process was so much like the others that they could just start it up from “experience”. But this new process had a “day tank” of which the other lines did not. This day tank has two automated “make-up” valves: one from the source and a return from the process. The tank only holds (LUCKILY) around 20 pounds of chlorine, but is inside an enclosed process building. The facility decided to execute their Initial Start-up procedures even though the PSSR was not completed; however, it had been completed on the Chlorine Cylinder building. The facility, without an Initial Start-up procedure, had operators close valves they thought needed to be closed so they could hook up their 1-ton cylinder to the new process. One of the valves that were verified to be closed were the two (2) make-up valves to the day tank. Just beyond the day tank, there was some last-minute work being completed by contractors. NO LOCKOUT was utilized as they were in… Start-Up Mode… so all the LOTO had been removed. When power was supplied to the process, the PLC saw that the Day Tank was “TOO LOW” so the make-up valves OPENED so as to fill the Day Tank and this provided a path to the workers on the other end of the pipe which was in a different building with NO chlorine detection or communications with the Cylinder building.
More to come… BUT this should have NEVER HAPPENED and I wanted to get this message out there to the SAFTENG members to ensure we know there is a difference in these phases of operations and process safety tasks.