The purpose of a Prestartup/Operational Readiness Review (PSR) is to ensure that initial start-ups, or start-ups following major project work, proceed safely and smoothly. As with most process safety activities a PSR will generally be performed by a small team made up of representatives from operations, maintenance, engineering, and safety.
The terms ‘Operational Readiness Review’ and ‘Prestartup Safety Review’ (PSSR) are used synonymously in this publication. ‘Prestartup Safety Review’ was used by OSHA in the 1990s in its Process Safety Management (PSM) rule. However, a safety validation of a facility will also help determine that the facility will operate as expected. Therefore the term ‘Operational Readiness’ is more comprehensive.
Prestartup Safety Reviews (PSSRs) are an integral part of all process safety management regulations. In the United States the requirements from OSHA (Occupational Safety and Health Administration) and the EPA (Environmental Protection Agency) are very similar to one another. Offshore facilities are regulated by the Bureau of Safety and Environmental Enforcement (BSEE) through their Safety and Environmental Management Systems (SEMS) rule. They use the term Prestartup Review (PSR). Once more, the content is similar to that of the OSHA and EPA rules.
What the Review Is Not
It is tempting to treat a Readiness Review as a chance to catch up on activities that should have been carried out earlier in the project. This temptation must be avoided. In particular,
- It is not the purpose of a Readiness Review to replace this normal “punching out” of the facility; that is done during the turnover of the system from the project team to operations and maintenance.
- The review is not an audit. The purpose of the review is to make sure that all work that had to be done prior to startup was in fact done, not to evaluate the work itself. Therefore, the review can be more flexible than an audit. For example, on one facility there had been times when operations personnel had bypassed by certain instruments without going through proper procedures. During a turnaround, the interlock system was upgraded in order to prevent such unauthorized over-rides. Part of the review was to have a knowledgeable and determined operator try to override the new interlock (while the facility was shut down) in order to see if he could “beat the system”. This type of activity would not be carried out during a conventional audit.
- The review is not a last-minute hazards analysis. The review team must simply check that the right types of hazards analysis were carried out at the right times, and that the quality of those analyses is satisfactory. The team must also check that all the findings were implemented or closed out in a professional manner. But the team does not analyze the new system for hazards.
- The review does not include evaluation of engineering designs or the checking of calculations. It may, however, ensure that the proper design standards were followed.
- The review is not part of the Management of Change (MOC) process. It is carried out once the MOC process has been completed.