Unlike the PHA, the PSSR provision does not specify a team, team qualifications, or sign-off. 29 CFR 1910.119(i)(2) requires that, prior to the introduction of highly hazardous chemicals, the PSSR confirm that construction and equipment are in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; a PHA has been performed for new facilities and recommendations resolved, and modified facilities meet MOC; and training of each employee involved in operating the process has been completed. How you staff and document that review is up to you, but you must be able to show each item was confirmed. OSHA has issued few letters on PSSR staffing; the ones below address when PSSR applies.
What OSHA Has Said
⚡ Key Compliance Takeaway
Because the standard sets the content but not the team, write your own PSSR procedure: who participates (operations, engineering, maintenance, and safety at minimum), who has authority to approve startup, and a checklist tied to each (i)(2) item. Keep the signed record. Inspectors will look for evidence that every item was verified before chemicals went in.

