Guidelines for Performing Effective Pre-Startup Safety Reviews

• Editorial: Wiley-Interscience
• Año: 2011
• ISBN:
  9781118215531
• Edición: 1
• Categoría: Tecnología e ingeniería
• Categoría: Ingeniería química y bioquímica

This book provides guidance to those with responsibility for scheduling and executing a Pre-Startup Safety Review (PSSR). It outlines a protocol and tool for use by project or turnaround teams, to effectively and efficiently schedule and execute a PSSR.

• Integrates PSSR throughout the project/turnaround phases, with a verification check at the traditional PSSR step
• Supports a "right first time" and "check only once" project philosophy to eliminate surprises
• Features how-to checklists, hazard assessment, batch and continuous processes, validation, and documentation
• Includes a CD with PSSR checklists and PSSR management system examples.

Note: CD-ROM/DVD and other supplementary materials are not included as part of eBook file.

CHAPTER 1

INTRODUCTION

The term pre-startup safety review (PSSR), in its simplest definition, means a final check prior to initiating the use of process equipment. When the term is used as a part of the overall process safety management program at a facility, it implies a management system within that program for ensuring that new or modified processes are ready for startup. This is accomplished by verifying that equipment is installed in a manner consistent with the design intent and that process safety management systems are in place. As each change, the associated risk, and the process in question may be unique, applying PSSR in a systematic way to your work processes simply represents a good business practice. Performing an effective pre-startup safety review is analogous to checking your math after performing a calculation or, for a more vivid analogy, checking your parachute before a jump.

In this book we examine the application of the practice of PSSR to the physical plant hardware, software, engineering, and management activities, and documentation associated with operating chemical processes. Although we focus on the chemical process industries (CPI) and specifically the associated process safety aspects, the concept of PSSR and its benefits apply to almost any human endeavor, especially in the manufacturing realm.

Since 1992, a major incentive for the chemical process industries (CPI) in the United States to make pre-startup safety review a part of day-to-day business practices has been the Occupational Safety and Health Administration’s (OSHA’s) process safety management (PSM) regulation (29 Code of Federal Regulations [CFR] 1910.119) (Reference 1-1). This regulation was followed by the Environmental Protection Agency’s (EPA’s) risk management program (RMP) rule (40 CFR 68) (Reference 1-2). These regulations are performance based and apply to facilities processing certain chemicals when present at or above specific threshold quantities. The term performance based means that each facility that falls under the regulation needs to meet certain minimum requirements, but how they meet those requirements is not prescriptive. A facility can build the PSSR program that best fits its risk levels, organizational culture, and resources.

However, other countries and industry organizations have recognized the importance of PSSR to process safety and have published similar rules or guidelines for using it. We will keep the general aspect of the concept of this "final check" in mind, address specific U.S. regulatory needs, but at the same time, give some specific examples of how global chemical processing companies apply pre-startup safety review to their operations to both comply with the applicable laws and enhance their manufacturing performance.

Whether implementing process safety management as a requirement or as a good practice, pre-startup safety review is essential to keeping the system alive and functioning properly to protect a facility against risk.

1.1 WHAT ARE THE BENEFITS OF PERFORMING PRE-STARTUP SAFETY REVIEWS?

There are many benefits to be gained from performing pre-startup safety review for your processes. A simple list includes:

• The change is more likely to operate as intended.
• The construction, maintenance, or programming work performed to build, install, or program the process change meets the design specifications originally intended.
• Pre-startup activities have been completed and post-startup activities are scheduled and tracked to help ensure that equipment is designed, fabricated, procured, installed, operated, and maintained in a manner appropriate for its intended application.
• New chemicals or materials used in the process are understood in regard to safety, health, environmental and material performance issues.
• Personnel assigned to inspect, test, maintain, procure, fabricate, install, or commission process equipment are appropriately trained and have access to current and up-to-date procedures and process safety information.
• In the event of an incident, a strong pre-startup safety review program documents corporate operational discipline and social responsibility.
• The safety systems are confirmed to be operating as designed.
• Engineering calculations and assumptions used for design and installation match recognized and generally accepted good engineering practices (RAGAGEP) which describe applicable codes and standards.
• Regulatory requirements for managing changes are met.
• Quality management system requirements for your company have been addressed.
• PSSR provides an opportunity for turnover of ownership from engineering or project managers to operations personnel

This book provides advice for developing a PSSR program that will assist organizations in achieving these benefits. Facilities should consider evaluating how they are doing in regard to reaping the benefits above. Chapter 7 – Continuous Improvement addresses this issue.

On a broader scale, effective PSSR supports any mature, well-designed PSM program by keeping the total program robust and vibrant in the face of change. The CCPS booklet The Business Case for Process Safety summarizes the benefits of process safety – and these same benefits are supported by performing effective pre-startup safety reviews:

“…methodically implementing process safety provides four benefits essential to any healthy business. Two of these benefits are qualitative and as a result are somewhat subjective. You can see them in the way the public, your shareholders, government bodies, and your customers relate to your company. The two remaining benefits are quantitative. These have measurable impact in terms of your bottom line and company performance. All four benefits, when realized together by adhering to a sound process safety system, combine to support the profitability, safety performance, quality, and environmental responsibility of your business.

• Corporate Responsibility – Process safety is the embodiment of corporate responsibility and accountability. It helps your company display these characteristics through its actions. The heart of process safety lies in consistently planning to do the right things, then doing them right - consistently. Corporate responsibility leads to the second benefit…
• Business Flexibility – Corporate responsibility as demonstrated in your process safety management program leads to a greater range of business flexibility. When you openly display responsibility through implementing an effective process safety program, your company can achieve greater freedom and self-determination.
• Risk Reduction – Process safety provides unparalleled loss avoidance capability. A healthy process safety program significantly reduces the risk of catastrophic events and helps prevent the likelihood of human injury, environmental damage, and associated costs that arise from incidents. Althou...