OSHA does not prescribe specific qualifications for PSSR team members, but it does require that the PSSR confirm that construction is consistent with design specifications, safety and operating procedures are in place, the PHA has been performed and recommendations resolved, and required training has been completed. These letters address who must be on the PSSR team, whether sign-off by a single engineer is sufficient, and how the PSSR interacts with MOC documentation. The PSSR is the final gate before HHC introduction and its completeness determines whether PSI, PHA, training, and MOC work actually reached the process.
What OSHA Has Said
Jan 30, 2001
PSSR Team Composition and Required Disciplines and Documentation
OSHA addresses who must participate in a PSSR. While specific qualifications are not mandated, OSHA expects the team to include personnel capable of confirming each checklist element, which generally requires engineering, operations, maintenance, and safety representation.
Read OSHA Letter ↗
Feb 7, 1996
PSSR Sign-Off and Single Engineer vs. Multi-Discipline Team
OSHA addresses whether a single engineer may complete and sign off a PSSR. OSHA position: a single individual may sign the PSSR document but must be capable of confirming all required elements, which in practice requires input from multiple disciplines.
Read OSHA Letter ↗
Jun 23, 2023
PSSR and MOC Documentation Integration
OSHA addresses the interaction between PSSR documentation and the MOC package. The PSSR should reference and close out open MOC items, training records, and PHA recommendations relevant to the modification.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
The PSSR is a gate, not a formality. Each checklist element must be genuinely confirmed. Include engineering, operations, maintenance, and safety in the review, and link the PSSR documentation to the underlying MOC package, training records, and PHA.