2022 Best Practice Audit Management

Most engineers in the chemical process industry talk about MOC with authority, but you rarely hear them mention PSSR in the same breadth. It seems that all of the elements of PSM are important for discussion but one...PSSR or Pre-Start-up Safety Review; but why? PSSR was, and is, as important as any of the elements of PSM/RMP/BSSE for two reasons. First, PSSR is a redundant check that a change has been reviewed, analyzed, approved and accomplished in a quality manner. In a “quality manner” means the change has been accomplished, usually by maintenance staff, in a manner acceptable by operations. The change must be completely done and well done. Secondly a PSSR is intended to be a check that all process safety information has been updated and all the training has been accomplished concerning the change. NOTE: It is not OK to startup a change without updates to PSI. Out of date PSI can be hazardous to your health. Beyond that, PSSR can be used when no MOC or change has occurred. After a turnaround or shutdown a pre-startup safety review is required. We might call this check something else like a Readiness Review or Punch List, but these are most surely a PSSR. PSSRs are required for all change that that requires a change to Process Safety Information (procedures, hazards of the process, technology, equipment, safe operating limits...). That covers about every change there is and a few more. Why do we talk so much about MOC and not so much PSSR? I think most people see it as redundant (not like in the UK where someone is let go), but as in unnecessary. That is flat out wrong. MOC and PSSR are not the same process and they may not even be connected or joined in some workflow with an MOC. This presentation covers the PSSR from end to end and gives it the full measure of respect it deserves.