A pre-startup safety review is required before any newly installed or modified process is introduced with a highly hazardous chemical. The triggering question is whether the change is significant enough to require a PSSR, or whether it was covered by the MOC process and does not constitute a startup. OSHA has addressed the distinction between a PSSR following a plant modification and a restart following a planned or unplanned shutdown, the requirement to conduct PSSR before HHC introduction not before mechanical completion, and what constitutes a new process requiring PSSR.
What OSHA Has Said
⚡ Key Compliance Takeaway
PSSR is a pre-HHC-introduction requirement. Plan PSSR into your turnaround and construction schedules so that all checklist items are confirmed complete before the first HHC enters the new or modified system. Do not mistake mechanical completion for PSSR completion.