Safety Moment #84: Prestartup / Operational Readiness Reviews

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. In particular, the PSR will check to make sure that all project activities are complete and that the system is ready for safe operation. It is a tool that the operations and maintenance departments use to make ensure that they have received what they expected to receive from the project team, and that no corners were cut, particularly with regard to safety.

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.)

Project Phases

The sketch shows the phases of a typical project and the time when an Operational Review is performed.

Mechanical completion means that the new system is completely built, that all equipment and instruments are installed, and that construction is complete. The equipment and piping should have been blown free of trash and housekeeping should be in good order. This phase of the project can be managed through turnover packages and punch lists that will allow both parties to check that the facility has been built as specified.

Each turnover package covers a discrete, self-contained section of the facility such as the instrument air header or the boiler feed water system. The use of turnover packages improves the speed and efficiency of the handover process because the facility can be divided into sections with clearly defined boundaries — the first completed sections can be handed over while work on other sections is still in progress.

Once a turnover package is complete the commissioning of that part of the facility can start. Commissioning can be organized into two phases: precommissioning and commissioning proper. Precommissioning is concerned primarily with cleaning out equipment and piping; commissioning focuses on checking the functionality of the equipment and instruments systems. One of the most important parts of the commissioning process is to circulate oil or hydrocarbon around and through all the equipment, gradually heating the circulating oil. Any pockets of water will be swept away and/or vaporized.

Once commissioning is complete the project team can transfer “Care, Custody and Control” from construction to operations. This is an important step because it means that the project team no longer has authority to make changes without going through the facility’s Management of Change program. From this point forward normal facility safe work procedures must to be followed. (It is also often a time when the contractor receives a substantial part of his.)

At the conclusion of the commissioning step the facility is declared “ready to go”. There may be a few last-minute, non-safety issues to clear up (such as painting and personnel protection insulation), but the path should be clear for implementing the Operational Readiness Review, thus leaving enough time to carry out any minor modifications, corrections or additions should any deficiencies be identified.

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.

Regulations

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 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.

Elements of Process Safety Management (PSM)

Throughout these Safety Moments we stress that Process Safety Management is a system consisting of multiple, interacting parts. The list below shows the elements as provided by the CCPS (Center for Chemical Process Safety). Those that are relevant to this Safety Moment are highlighted.

1. Process Safety Culture
2. Compliance
3. Competence
4. Workforce Involvement
5. Stakeholder Outreach
6. Knowledge Management
7. Hazard Identification and Risk Management
   his could be the most important element to cross check. The review should ensure that all hazards analysis findings have been properly addressed. In particular, all safety recommendations should have been implemented and closed out.
8. Operating Procedures
   Most facility modifications require new or updated operating procedures to be written and published.
9. Safe Work Practices
10. Asset Integrity / Reliability
11. Contractor Management
12. Training / Performance
    Just as new or modified procedures are needed, so operations and maintenance personnel will require updated training.
13. Management of Change
    The review should check that all MOC procedures have been followed, and findings closed out.
14. Operational Readiness
15. Conduct of Operations
16. Emergency Management
    The review should check that the emergency response procedures and equipment have been modified, as needed.
17. Incident Investigation
18. Measurement and Metrics
19. Auditing
20. Management Review

Further Information

For more information to do with Prestartup reviews, please refer to Chapter 8 of the book Process Risk and Reliability Management, or the ebook Prestartup Reviews. The Table of Contents for the ebook is shown below.

---

Introduction
What the Review Is Not
Regulations
   OSHA’s PSM
      (i)  Construction and Equipment
      (ii)   Procedures
      (iii)  New / Modified Facilities
   BSEE    
   EPA 
Types of Review    
   Review Not Required   
   Small Projects / Engineering Changes   
   Medium Size   
   Large Projects    
   Restart Reviews 
Organization of a PSR   
   Time Required
   Team Structure
Using the Elements of Process Safety Management
   Compliance   
   Knowledge Management
   Operating Procedures
   Asset Integrity / Reliability
   Training / Performance   
   Management of Change
   Management Review

---