What Is Pre-Startup Safety Review Under PSM?
The Pre-Startup Safety Review is a verification requirement that applies whenever a new process facility is commissioned or when modifications to an existing facility are significant enough to require a change in process safety information. The PSSR is the final safety gate before introducing highly hazardous chemicals into a new or modified process.
OSHA requires that the PSSR confirm four things: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and are adequate; a PHA has been completed and recommendations resolved; training of each employee involved in operating a process has been completed.
The PSSR is not just a paperwork exercise — it is a physical walkdown and verification. Equipment must be inspected against P&IDs. Procedures must actually be written, current, and accessible. The PHA must be complete. And operators must be trained — not just scheduled for training.
What the Standard Actually Requires
- 1Scope Trigger — Required for all new processes and for modified processes where changes require PSI updates.
- 2Construction Verification — Physical verification that construction and equipment conform to design specifications.
- 3Procedure Readiness — Safety, operating, maintenance, and emergency procedures must be in place, complete, and accessible before startup.
- 4PHA Completion — A PHA must be completed and recommendations resolved before introduction of HHCs.
- 5Training Completion — Training of all employees involved in operating the process must be complete.
Common Violations OSHA Cites
These are the deficiencies inspectors most frequently document in Pre-Startup Safety Review programs. Each can represent a separate citation.
Frequently Cited Violations
- PSSR not performed for a modification that required changes to process safety information
- PSSR completed but PHA recommendations were still open at startup
- Operators started up new/modified process without completed training documented
- PSSR was a paper review only — no physical walkdown to verify equipment against P&IDs
- No documentation that PSSR was performed
What Inspectors Look For
- Requesting PSSR records for the last 2-3 major projects or modifications at the facility
- Cross-referencing PSSR date against training completion dates for affected operators
- Reviewing open PHA recommendations at the time of PSSR to check for premature startup
- Comparing PSSR checklist scope against the full MOC scope to identify gaps
Consequences of Pre-Startup Safety Review Failures
Premature startup — introduction of HHCs before all PSSR requirements are satisfied — is a known high-risk scenario. The 2005 BP Texas City disaster involved startup of a process where procedures were inadequate and operators were not properly trained, conditions that a thorough PSSR would have identified and prevented.
Penalty Exposure — Pre-Startup Safety Review
OSHA penalty range for Pre-Startup Safety Review violations: $4,000-$15,625 per violation. PSSR violations are typically cited as serious, but can be elevated to willful when employers can demonstrate awareness of the requirement and chose to proceed without conducting the review.
Documents Your PSSR Program Needs
An OSHA compliance inspection for Pre-Startup Safety Review will typically request the following. Gaps in any of these areas may result in citations.
Required Documentation
- PSSR checklist and completed PSSR records for each new/modified process
- PSSR team qualification records
- Cross-reference of PSSR against current P&IDs
- Open PHA recommendation status at time of PSSR
- Operator training completion records pre-dating PSSR clearance
Related LOI Guidance
OSHA has clarified these specific questions about the Pre-Startup Safety Review element through official Letters of Interpretation:
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