The Pre-Startup Safety Review (PSSR) is the final verification step that confirms everything is safe before a new or modified process begins operating. Under 29 CFR 1910.119(i), employers must perform a PSSR for new facilities and for modifications significant enough to require a change in process safety information. The PSSR is closely tied to management of change and serves as the quality gate between planning a change and operating under new conditions. Ecesis PSM software integrates PSSR checklists directly into the MOC workflow to ensure no startup occurs without proper review.
What OSHA Requires
Under 29 CFR 1910.119(i), the employer must perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in process safety information. The review must confirm that:
- Construction and equipment are in accordance with design specifications
- Safety, operating, maintenance, and emergency procedures are in place and are adequate
- For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup
- Modified facilities meet the requirements contained in management of change (1910.119(l))
- Training of each employee involved in operating a process has been completed
Step-by-Step Implementation
Define PSSR Triggers
Clearly define which situations require a PSSR. At minimum, PSSRs are required for:
- New process installations
- Process modifications significant enough to require changes to process safety information
- Changes approved through the MOC process
Best practice also includes PSSRs for startups following extended shutdowns, major turnarounds, and equipment replacements that are not in-kind. Document your criteria and train operations and maintenance personnel to recognize when a PSSR is needed.
Develop PSSR Checklists
Create standardized checklists that systematically verify each OSHA requirement. A typical PSSR checklist addresses:
- Construction verification: Equipment installed per design drawings, piping connections verified, instrumentation calibrated and tested, electrical installations complete and inspected
- Documentation verification: P&IDs updated, operating procedures revised, maintenance procedures updated, emergency procedures updated
- Safety system verification: Interlocks tested, alarms tested, relief devices installed and set correctly, fire protection systems operable
- Training verification: All affected operators trained on changes, training documented, comprehension verified
- PHA/MOC verification: PHA completed (new facilities), MOC requirements met (modifications), all recommendations resolved
- Housekeeping: Construction debris removed, temporary blinds removed or documented, area clean and safe for operations
Integrate PSSR with MOC Workflow
The PSSR should be a mandatory step in your MOC closure process. No MOC should be closed, and no modified process should be started up, until the PSSR is completed and approved. Configure your MOC workflow so that:
- The PSSR checklist is automatically generated when an MOC is approved for implementation
- PSSR completion requires sign-off from operations, maintenance, and safety personnel
- Startup authorization is blocked until the PSSR is documented as complete
- Any PSSR deficiencies are resolved before startup or formally accepted with interim protective measures
Document and Retain PSSRs
Complete PSSR documentation including:
- The completed checklist with specific verification items checked and signed
- Names and roles of the PSSR team members
- Date of review and date startup was authorized
- Any deficiencies identified and how they were resolved
- Reference to the associated MOC number (for modifications)
Retain PSSRs as part of your MOC files and PSM program records for audit review.
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software integrates PSSR directly into your change management process:
- MOC integration: PSSR checklists are embedded in the MOC workflow, preventing closure until all verification steps are completed and signed
- Inspection tools: Conduct PSSR field verifications using the mobile app with photo documentation and electronic sign-off
- Training verification: Confirm training completion for affected personnel directly within the PSSR workflow
- Task tracking: Track PSSR deficiencies to resolution before startup authorization is granted
Frequently Asked Questions
Does every MOC require a PSSR?
A PSSR is required when a modification is significant enough to require a change in process safety information. Minor changes or administrative MOCs may not trigger a PSSR, but best practice is to define clear criteria and err on the side of conducting the review when in doubt.
Who should be on the PSSR team?
OSHA does not specify PSSR team composition, but the team should include personnel capable of verifying each element: operations (procedures and training), maintenance or engineering (construction and equipment), and safety (safety systems and PHA recommendations). For major changes, include the MOC originator.
Can a PSSR be completed in stages?
Yes, for large or phased projects, PSSRs can be completed in stages as different portions of the project are ready for startup, provided each stage is independently verified and documented before the associated process section is placed in service.
What if a PSSR finds a deficiency?
The deficiency must be corrected before startup, or formally documented with interim protective measures and a corrective action plan if the deficiency does not create an imminent hazard. The decision to proceed with interim measures should be made by qualified personnel and documented.
How long should PSSR records be retained?
OSHA does not specify a retention period for PSSRs, but since they are closely tied to MOC records, retaining them for at least the life of the process or equipment change is best practice. Many facilities retain PSSRs until the next PHA revalidation confirms the change is incorporated.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
