Pre-Startup Safety Review

DOE-HDBK-1101-96

2.7 Pre-Startup Safety Review

29 CFR 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.

(2)

The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a

process:

(i)

Construction and equipment are in accordance with design specifications;

(ii)

Safety, operating, maintenance, and emergency procedures are in place and are adequate;

(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).

(iv)

Training of each employee involved in operating a process has been completed.

Intent

The purpose of PSRs is to ensure the following.

New or modified facilities and equipment are built and installed in accordance with design

requirements.

All process procedures and related process operator training are adequate and completed

prior to the introduction of hazardous materials into the process.

Adequate safety reviews are conducted

All PrHA safety recommendations are complete prior to startup.

PSRs are important in MOC procedures after a process has been modified [Q74] or shut down for

process safety-related reasons.

Corresponding DOE Programs and Requirements

DOE readiness reviews serve many of the same functions as PSRs. PSRs completed for processes

covered by the PSM Rule support DOE readiness review requirements.

Operational readiness reviews are currently required for start and restart of nuclear facilities under

DOE O 425.1, STARTUP AND RESTART OF NUCLEAR FACILITIES. There is a general

requirement for readiness reviews for new facilities under DOE O 430.1, LIFE CYCLE ASSET

MANAGEMENT.

Documentation Requirements

PSR documentation includes a checklist of items reviewed and the resulting action plan. (A sample

PSR checklist is provided at the end of this section.) DOE contractors should use a graded approach

to conducting PSRs. For simple processes, it may be adequate to complete a form with appropriate

authorization blocks indicating that the covered process is ready for startup. Information should be

documented by checklists and formal readiness review plans for initial startups or following a safety-

related shut-down. This documentation, with the appropriate approvals, must be maintained on file