Pre-Startup Review )

Pre-Startup Review )  

What the regulation says: (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. (i)(2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: (i)(2)(i) Construction and equipment is in accordance with design specifications; (i)(2)(ii) Safety, operating, maintenance, and emergency procedures are in place and are adequate; (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). (i)(2)(iv) Training of each employee involved in operating a process has been completed.

What it means:  For new processes, the employer will find a PHA helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process will be enhanced by making use of the PHA recommendations before final installations are completed. P&ID’s are to be completed along with having the operating procedures in place and the operating staff trained to run the process before startup. The initial startup procedures and normal operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters. For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than "replacement in kind" made to the process during shutdown go through the management of change procedures. P&ID’s will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and non-routine work in the process area may need some refresher or additional training in light of the changes. Any incident investigation recommendations, compliance audits or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before the introduction of an HHC to the new or modified process.