Pre-Start-Up Safety Review

It is important that a safety review takes place before any highly hazardous chemical is introduced into a process. PSM, therefore, requires the employer to perform a pre-start-up safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Prior to the introduction of a highly hazardous chemical to a process, the pre-start-up safety review must confirm the following:

  • • Construction and equipment are in accordance with design specifications.
  • • Safety, operating, maintenance, and emergency procedures are in place and are adequate.
  • • A PHA has been performed for new facilities, recommendations have been resolved or implemented before start-up, and modified facilities meet the management of change requirements.
  • • Training of each employee involved in operating a process has been completed.

Mechanical Integrity

OSHA believes that it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly. PSM mechanical integrity requirements apply to the following equipment:

  • • Pressure vessels and storage tanks
  • • Piping systems (including piping components such as valves)
  • • Relief and vent systems and devices
  • • Emergency shutdown systems
  • • Controls (including monitoring devices and sensors, alarms, and interlocks)
  • • Pumps

The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employees' job tasks.

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must conform to manufacturers' recommendations and good engineering practices, or exceed these if determined to be necessary by prior operating experience. Each inspection and test on process equipment must be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation.

In constructing new plants and equipment, the employer must ensure that equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The employer also must ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

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