A Pre-Startup Safety Review (PSSR) is a formal, documented safety verification required before the initial startup of new or modified process equipment. PSSR is a regulatory term — it is explicitly mandated by OSHA 29 CFR 1910.119(i) under the Process Safety Management (PSM) standard and by EPA 40 CFR Part 68 under the Risk Management Program (RMP). It is not a defined term in IEC 61511-1.
While PSSR originates from process safety regulation, equivalent activities appear in the IEC 61511 safety lifecycle. The validation phase (Clause 15) and functional safety assessment (FSA) steps confirm that safety instrumented systems (SIS) are correctly installed, commissioned, and tested before startup. Facilities subject to both IEC 61511 and PSM or RMP typically satisfy the PSSR requirement through their validation records and FSA documentation.
Key Points:
- Required by OSHA PSM (29 CFR 1910.119(i)) and EPA RMP (40 CFR Part 68) before startup of new or modified covered processes
- Confirms equipment, SIS, alarms, and safety interlocks are installed and tested per approved design
- Verifies operating procedures are in place, personnel are trained, and PHA action items are closed
- In IEC 61511 terms, PSSR activities align with the validation phase (Clause 15) and FSA requirements
- Triggered by new installations and by changes processed through a management of change (MOC) program
Example:
Before starting up a newly installed SIS on a gas compressor, the PSSR team confirms site acceptance testing is complete, operating procedures are approved, HAZOP action items are closed, and operators are trained. The signed PSSR record satisfies the PSM and RMP regulatory requirements and aligns with IEC 61511 pre-startup validation activities.
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