PSSR

PSSR

Who is the

PSSR Gatekeeper

for your facility?

PSSR is not about filling a bunch of forms.

Hazard Analysis

Codes & Regulatory Requirements

MOC

PSSR

"Risk Based"

Process Safety Information

Training

Critical

Construction &

Installation

tasks

Operation & Maintenance Procedures

Question:

"Authenticated As-Built" or

"Red-Lined"

PSSR

How about this?

Maintenance

Emergency

Operation

Emergency Procedures

Replacement in-kind of a major section

Risk = Likelihood x Severity

"Risk Based"

But prudent to do

- How likely is it for something to go wrong

- How severe would be the

consequences if something

goes wrong?

- Major change vs. minor change

PSSR

- Highly toxic / flammable chemicals

- Complex vs. simple processes

- Chance of fatality or severe injury

How about this?

- Well-known vs. novel processes

- $value

- Whether PSSR is required

Starting up a 'Mothballed' Process

- To what level of details

No regrets after starting up a new / modified process

But prudent to do

Not Always

Black & White

Summary:

(as a minimum)

PSSR is not required for every MOC.

• PSSR is required for ALL new processes

Examples:

- Construction / Installation tasks not completed

• PSSR is required for modified processes if the change impacts PSI's.

- No hazard assessment was performed or

the findings of the hazard assessment

reviews were not completely addressed.

What is the criterion?

OOPS!

Some decision making is involved

- No training for operators / maintenance crew

PSSR is generally required when a

Changes:

Unplanned / Uncontrolled Release of

Hazardous Materials / Energy

- Not updating the technical documents,

operating / maintenance procedures,

emergency procedures, ...

modification impacts

PSSR &

Temporary Changes

'In-Kind'

'Not-In-Kind

"Process Safety Information (PSI)"

• MOC is a must

Different Reasons:

• No MOC

• No PSSR

• How about PSSR?

• PSSR before putting new / modified process in service

Information / documents which are essential from "process safety" perspective.

• PSSR after removing the temporary changes

• ...
• ...
• Starting a new / modified section of a process when it is not completely ready
• ...

Are there any

delegates?

PSSR

Gatekeeper

Changes Not Requiring PSSR

What is this PSI?

- New process

Lots of Man Power & Unnecessary Delays in some projects

Accidents / Losses

Information pertaining to:

Conducting PSSR when there are risks and at a level of details commensurate to the risk ranking

- Modified process

• Change in operating or maintenance procedures

• Hazardous nature of chemicals

Safety Data Sheet

• Physical Properties
• Toxicity
• Corrosivity
• Thermal & Chemical Stability
• Permissible Exposure Limits
• Hazardous effects of inadvertent mixing

Understands sensitivities / vulnerabilities

• Process Equipment

Information Pertaining to Process Equipment:

• Equipment Data Sheets

• Mechanical Drawings

• Applicable Codes & Standards

• Process Technology

Information Pertaining to Process Technology:

Catalyst B

Catalyst A

• Process Chemistry
• Materials & Energy Balance Calc.
• Block Flow Diagram
• Process Flow Diagram
• P&ID
• Safety Systems (e.g. interlocks or suppression systems)
• Maximum Intended Inventory
• Safe Upper / Lower Operating Limits
• Relief System Design
• Ventilation System Design
• Electrical Classification

Strong Supporter of PSSR & PSM

• Change in piping layout ( no change on P&ID)

No PSSR

Sufficient authority

Detailed PSSR for Every Project / MOC

When is PSSR needed?

What is PSSR

and why is it needed?

PSSR:

- A PSM Element

- Overlap with other

PSM elements

PSSR

Pre-Startup Safety Review

How is PSSR conducted?

Roles & Responsibilities

PSSR Gatekeeper

(Asset Owner)

- Operations Superintendent.

- Decide if PSSR is needed.

- Determine the level of details for a PSSR.

- Appoint a delegate or PSSR Coordinator/Leader.

- Authorize start-up.

- Sign-off the completion of PSSR.

PSSR Gatekeeper / Asset Owner

PSSR Coordinator / Delegate

PSSR Leader

- Appointed by PSSR Gatekeeper

- To be involved in details

- Contributes in the decision about PSSR team members

- Schedules PSSR meeting(s)

- Facilitates PSSR meeting(s)

- Ensures PSSR forms are completed / signed.

Project Manager / Change Owner

- Advise when the MOC / Project is ready for PSSR.

- Contribute in the decision for PSSR team members.

- Ensure all required pre-work are completed.

- Give an overview of the change / project during PSSR meeting

- Follow up on CRITICAL deficiencies to have them completed

before start-up / commissioning.

Deficiency: A finding which needs to be rectified before a MOC or Project can be considered as complete.

Critical Deficiency:

A deficiency which needs to be rectified before putting the new or modified system in service.

Non-Critical Deficiency:

A deficiency which is not a prerequisite for start up but it needs to be completed before the MOC or Project can be signed off as complete.

- Follow up on NON-CRITICAL deficiencies to have them completed

before final sign-off of the PSSR.

High Risk PSSR Checklist:

- Documentation

- Training / Communications

- Field Verification

(SMEs)

PSSR Team

- Participate in PSSR review(s).

- Assess the potential hazards.

- Identify deficiencies.

- Classify deficiencies into CRITICAL and NON-CRITICAL.

- Advise if deficiencies have been properly resolved.

PSSR Coordinator

Change Owner / Project Manager

PSSR Team / SMEs

Pre-Startup Safety Review

Subject Matter Experts

Question Time!

it is safe to put a new / modified process in service.

Compliance with codes and legal requirements

Completion of Process Hazard Analysis and its rec's

Ensuring that:

The change or project has been managed through appropriate processes (e.g. MOC process)

PSI documents have been revised as required or new PSI documents have been prepared as needed.

SOP's have been revised or new SOP's have been created.

Adequate training for the workforce

Also, PSSR stakeholders should be trained on how the PSSR process works and their roles and responsibilities.

Risk Based PSSR means when deciding about the following two aspects of PSSR, the level of risks associated with a modified or new process must be taken into consideration:

- Whether or not PSSR is required

- What type of PSSR (what level of details) is more appropriate

PSSR Gatekeeper (Asset Owner, Ops Sup.)

Piping & Instrumentation Diagram (P&ID)

MSDS

Equipment Data Sheets / Drawings

Other PSI Documents:

Process Description (including process chemistry)

Maximum Inventory of Hazardous Materials

Materials & Energy Balance

Block Flow Diagram (BFD) and / or Process Flow Diagram (PFD)

Piping Specification

Cause & Effect Table

Process Control Documents — Distributed Control System (DCS)

Process Control Documents — Safety Instrumented Systems (SIS)

Process Control Documents — Others

Process Equipment Drawings

Process Equipment Layout

Hazardous Area Classification

Relief System Design (including design basis)

Ventilation System Design

Hazardous Mixing of Chemicals

Safe Operating Limits (SOL)

Applicable Codes, Standards, and RAGAGEPs

x

SMEs

Question:

Name 3 bases which are covered by performing PSSR.

Explain the relationship between "PSSR" and:

"PSSR" is a requirement of ...

- Codes and regulatory requiements are met.

How about other PSM elements?

- Change has been managed through MOC.

- Hazard Evaluation has been completed.

- Training

- Technical documents and procedures have been updated / created.

- Personal Safety

- Transportation Safety

- Process Safety

One of the areas which are verified during PSSR is about having adequate training for those who will be operating or maintaining the new or modified process.

Also PSSR stakeholders should be trained.

- All critical construction and installation tasks have been completed.

- PSI

- Workforce has received training.

PSSR team will ensure that PSI documents are properly revised / created to accurately reflect the new or modified processes.

Question:

PSSR is .... for new additions .

What does RISK BASED PSSR mean?

PSSR is required for all 'not-in-kind' changes.

- a must

PSSR should be done when there is a risk for starting up a project.

- a must (if any of the PSI documents is impacted)

- True

Also, level of details for a PSSR depends on the risk ranking for the project.

- False

Question:

Name 3 PSI documents?

If a modification causes change in PSI documents, then ....

- P&ID

Piping Layout and Piping Isometrics are part of the PSI documents.

- MSDS

- Equipment DSH / DWG

- PSSR is a requirement

- Pressure Relief System Design Doc's

- True

- Control Systems Design Doc's

- False

- PSSR is only recommended.

- .....

Question:

If a modification does not cause any changes in PSI documents then ....

Is PSSR required when upgrading the governor system for a turbine?

Can the PSSR Gatekeeper & PSSR Leader be the same person?

- PSSR is not required

Yes

Yes

- according to principles of RISK BASED

PSSR it might be wise to perform PSSR

if the risk is significant.

Question:

If the size of a control valve is changed, are we required to perform PSSR? Why?

How can we reduce the review time for a PSSR?

Who makes the final decision about whether or not PSSR is needed for a MOC or Project?

Yes, because it is impacting PSI documents.

"Preparation"

PSSR Gatekeept

(There are risks associated with this change; "RISK BASED PSSR")

(Asset Owner)

- Make sure all the records are

availbe for the review team.

- Make sure PSSR team members

are familiar with the project.

Question:

Is there any other questions about PSSR?