(53e) The PATH to Safe START-up - a Change in PRE-Startup Safety Review (PSSR) Perspective

Author: Rae-Ann Joseph

Atlantic LNG Company of Trinidad and Tobago

Point Fortin

Trinidad & Tobago

Title: THE PATH TO SAFE
START-UP - A CHANGE IN PSSR PERSPECTIVE

Biography

Rae Ann Joseph is a Process Safety and Risk Engineer employed with the
Atlantic LNG Company of Trinidad and Tobago. Ms. Joseph received her Bachelor
of Science in Chemical Engineering (with honors) from the Florida A & M
University, and a Masters of Business Administration from Springhill College in
Mobile, AL. She is currently a senior member of the American Institute of
Chemical Engineers, and a registered certified engineer with the Board of
Engineering (BOETT) and the Association of Professional Engineers of Trinidad
and Tobago (APETT).

Rae-Ann Joseph has roughly fourteen years of experience in process
engineering, capital project, process safety and risk management in the
chloro-alkali and LNG industries. She’s helped to implement her company’s
current Asset Integrity management program and the Operational Risk Register.
She is a champion for Project risk management and Bowtie development, and leads
various process safety improvement initiatives in her current role at Atlantic
LNG.

The
Path to Safe Startup

Process installations and changes to a manufacturing facility
are required to go through a Management of Change (MoC) process, and are often
undertaken as part of a project. The MOC or project owner is required to
develop a scope, provide a basis or justification for the change, identify and
address the risks associated with this change, provide training for those
impacted by the change, and verify that the installation or change is fit for
purpose before startup (commissioning). This verification process prior to
start up is accomplished by means of a pre-startup safety review (PSSR). A PSSR
may also be required in other instances such as restarting a mothballed
process, after major maintenance activities on equipment, or following a major
process upset or emergency shutdown.

What is a PSSR?

The Pre Startup Safety Review (PSSR) is a formal review of a
manufacturing process to verify that critical areas of the affected process
have been assessed and addressed prior to using the process. Using the process
could include: commissioning, introducing hazardous chemicals, or introducing
energy (CCPS, 2007).

Why the need for a
PSSR? 

A PSSR is required to verify that a plant or installation is
safe to start up and to confirm operational readiness of the plant, the people
and the processes affected by the installation. In summary, the primary purpose
of the PSSR process is to verify that the installation has met its design,
safety, quality and operability objectives. The main objectives of
the PSSR process is to ensure3:-

1. The installation meets the original design and operating intent
2. Adequate safety reviews and risk assessments were performed during design
3. All required safety considerations and action items are completed and included during construction
4. Site modifications during construction have been properly controlled and documented
5. Safety, operating, maintenance and emergency procedures are in place and adequate
6. Training of each employee involved in the operating process
7. The Operations group has an opportunity to refuse or accept responsibility for any installation or equipment that they may deem to be unsafe for start-up or operate.

A PSSR is conducted
by a multi-disciplinary team comprising experienced persons who are knowledgeable
enough about the process or installation to verify its readiness for startup. 

Examples of PSSR checks conducted
by the team include:

1. Technical integrity of design and engineering
2. Installation in field meets original design and intent
3. Training and procedures for affected personnel
4. General safety considerations for the installation
5. Equipment / machinery safety considerations
6. Occupational Health and Industrial hygiene impacts
7. Process Technology and Process Hazard considerations
8. Mechanical Integrity Concerns
9. Quality Assurance / Quality Control checks
10. Environmental Impact or concerns e.g. noise, emissions
11. Interlocks and Alarm Management changes
12. Emergency Response Procedures changes
13. Process Safety Information updates e.g. P&IDs, Equipment registers
14. Human Factor considerations
15. Labeling of items in the field

This paper evaluates the need for a shift in perspective of
the PSSR process from a “pre-startup safety review” to a “path to safe startup
review” and how this approach can lead to a more successful outcome for the
PSSR process and the project.

The
PSSR End Goal

The end goal for every
engineer when doing a process change or installation is its safe and effective
startup and operation. If one were to work backward from that end goal, one
would place focus on project factors and decisions with the greatest potential
to impact a successful outcome. In the context of PSSR, project success can be
measured by how well the installation meets its objectives for safe startup and
operation.

Based on the trend
illustrated in the Project Influence vs Cost curve shown below, one can agree that the greatest ability to influence the success of a
project takes place in the early stages i.e. planning and design. This
principle should apply to all aspects of project success whether it is safety,
quality, design or schedule. The foundation for a successful and safe
implementation or change lies in the planning and design stages of the project
and continues to build up in the construction and execution stages.

Figure
1: Project Influence vs Cost curve

The
Reality of PSSRs

Often the PSSR process is viewed as an activity or checklist
to be conducted just before startup and typically begins post construction or
pre-commissioning. The very name of the process implies that it should be
initiated just before start-up, when in actuality, the PSSR process should be
seen as a path to safe startup and operation from design to execution.

An assessment was conducted for various PSSR checklists to
identify best practice considerations used for this process. This assessment
also revealed the following:-

·        
PSSR checklist questions
essentially seek to determine whether the PSSR process objectives have been
met.

·        
The majority of PSSR
checklists consist of approximately one hundred (100) or more questions.

·        
The PSSR questions are
categorized to ensure all aspects of the installation or change are evaluated.

·        
A thorough PSSR requires a
significant investment of time and resources in order to be effective.

·        
The majority of PSSR
checklist questions seek to verify items that are typically implemented during the
design and construction stages, not start-up.

To demonstrate this final point, standard PSSR checklist
questions were evaluated and placed in the most suitable project stage to
address the concern of interest. As seen below (Figure 1), the majority of these checks fall under design
activities and taper down to final verification checks at pre-startup. This is
a similar trend to the Project vs. Influence curve (Figure 3).

Figure 2:
PSSR checks conducted at each project stage

Opportunities
to Improve the PSSR Process

The Process

Considerations must be
given to all impacted areas to ensure adequate design for major areas such as
risk management, operability, maintainability and environmental impact in the
early stages. By applying the concept of front end loading in the early stages, the project engineer can address key concerns early and maximize the
potential for a successful startup.

Certain PSSR considerations need to be identified during
design, tracked and implemented during construction, and verified as completed before
startup. If one waits until pre-startup to verify the changes are acceptable
and complete, one may find design flaws and omissions that are impractical or
impossible to address adequately due to limitations around cost, schedule and
finality of construction.

The Plant

The most common method to verify a plant’s readiness for
startup is mechanical completion. Mechanical Completion (MC) is a final phase
of construction activities to verify completeness of the plant that each
installed component is fabricated, installed and tested in accordance with the
project design specifications and procedures after all mechanical works,
including pre-commissioning activities are completed. Some minor works
which are not safety and performance related can be performed during
commissioning and operation.

While
an MC certificate is mandatory to initiate a PSSR for major projects, it is not
always mandatory for minor projects and process changes. It is recommended that
equivalent completion processes on a smaller scale be identified and
implemented in the PSSR process to provide the same rigor and assurance as MC
for minor process changes. The field walkdowns and hands on equipment checks
will provide the final physical verification of completion and identify
non-conformances that need to be addressed prior to startup.

The People

Competence and readiness of persons
involved with or affected by the installation should be treated with utmost
importance. Proof of communication to employees impacted by the change can be
verified using training records and update of procedures, P&IDs and similar
process safety information.

While documentation is acceptable, it
may fail to confirm the communication feedback loop is complete. Simply put, is
the change fully understood by those tasked with performing the tasks or
activities associated with the change? How does the change affect operator
response to new alarms? Have we done a thorough human factors evaluation around
the change? There is room to improve how we assess operator readiness following
a change.

Conclusion

A successful PSSR requires the
evaluation of a significant number of questions based on various disciplines
during pre-startup. Several of these questions arise from concerns that should
be identified in the early project stages, and verified before construction or
at the soonest opportunity to ensure concerns are addressed in a timely manner.
There is insufficient time during the pre-startup window to perform thorough PSSR
checks for process, plant and people readiness.

Failure to perform timely PSSR checks
for each discipline can impact the safety, quality, and operability of the
installation, and result in addition to cost and schedule if change is
necessary. Facilities should consider streamlining and improving their PSSR
process with the recommendations put forth to achieve safe startup and
operation and increase the likelihood of successful project delivery.

References

1. Center for Chemical Process Safety (2007) Guidelines for Performing Effective Pre-startup Safety Reviews, John Wiley & Sons, Inc., Hoboken, NJ, USA.
2. https://www.aiche.org/ccps/resources/glossary/process-safety-glossary/pre-startup-safety-review-pssr
3. http://www.enggcyclopedia.com/2012/05/pre-startup-safety-review-pssr/
4. http://www.lauromuller.co/quick-introduction-project-planning/