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The Electronic Newsletter of The Industrial Refrigeration Consortium

Vol. 10 No. 3, 2010

PRE-STARTUP SAFETY REVIEW

ABSTRACT
In this issue of the Cold Front, we discuss the Pre-Startup Safety Review (PSSR) element of the Process
Safety Management (PSM) standard. Just like with the Management of Change (MOC) article appearing the
in the last issue of the Cold Front, if your facility does not fall within the scope of the PSM standard
because the inventory of ammonia is less than the threshold quantity (e.g. 10,000 lb) or because it is located
outside the U.S., the information contained within this article is still important to ensure that the safety of
your industrial ammonia refrigeration system is not compromised when starting up new or modified portions
of the system.

INTRODUCTION
Pre-startup Safety Review (PSSR) can be viewed in straightforward terms as a quality assurance program for
modifications to the design, or control of a covered process such as an industrial ammonia refrigeration
system. Given that description, it is clear that PSSR is a critical part of managing changes to the system and

IRC Staff In This Issue

Director • PSSR 1-6
Doug Reindl 608/265-3010
or 608/262-6381 • Upcoming Ammonia Classes 2
dreindl@wisc.edu
• Noteworthy 2
Assistant Director
Todd Jekel 608/265-3008 • Refrigerant Inventory 7
tbjekel@wisc.edu Web course
Research Staff • Engineering Safety Relief 8
Dan Dettmers 608/262-8221 Systems Web course
djdettme@wisc.edu

IRC Contact Information Mailing Address

Toll-free 1-866-635-4721 1513 University Avenue
Phone 608/262-8220 Suite 3184
FAX 608/262-6209 Madison, WI 53706
e-mail info@irc.wisc.edu Web Address www.irc.wisc.edu

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ensuring that changes are implemented without incident.

The PSSR serves not only to check that a project has been
constructed in accordance with the design and
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associated engineering specifications but it also verifies C
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the required PSM elements are in-place and functioning
PRIOR to startup. Inventory Calculation Brown Bag
October 29, 2010 or
November 29, 2020 via. the web
Recognizing that the PSSR could be considered as the
quality assurance program for managing change, it Principles & Practices of Mechanical
shouldn’t be surprising that the PSSR element is closely Integrity for Industrial Refrigeration
linked to the MOC element – together functioning to: Systems
November 3-5, 2010 Madison, WI
• assure no unintended hazards are introduced
• assure risks are properly evaluated & minimized Intermediate Ammonia Refrigeration
December 1-3, 2010 Madison, WI
• assure that the PSM program is kept up-to-date:
process safety information, hazard analyses, Engineering Safety Relief Systems
operating procedures, training, mechanical December 6-10, 2010 via. the web
integrity procedures, and emergency planning
and response procedures. Process Safety Management Audits for
• be applied during the life of the project & Compliance and Continuous Safety
completed before changes are implemented Improvement
January 26-28, 2011 Madison, WI
This issue of the Cold Front is focused on helping
you understand more clearly what types of situations Energy Efficiency Improvement Strategies
should be considered for the PSSR process. for Ammonia Refrigeration Systems
February 9-11, 2011 Madison, WI
SCOPE FOR PSSR
The scope of the PSSR process can be ascertained by Introduction to Ammonia Refrigeration
considering section (i)(1) of the PSM standard which Systems
states: March 2-4, 2011 Madison, WI

Ammonia Refrigeration System Safety

1910.119(i)(1): The employer shall perform
April 18-20, 2011 Madison, WI
a pre-startup safety
review for new facilities
and for modified Design of NH3 Refrigeration Systems for
facilities when the Peak Performance and Efficiency
modification is September 19-23, 2011 Madison, WI
significant enough to
See http://www.irc.wisc.edu/education/ for
require a change in the
more information.
process safety
information.

Seems pretty straight-forward, but are there

Noteworthy
• Schwan’s & Target have joined the IRC!
• Send items of note for next newsletter to Todd Jekel, tbjekel@wisc.edu.

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modifications that require a change in the process safety information (PSI) that could be considered less than
significant?

Can we simply apply the same logic to a PSSR that we applied to the Management of Change (MOC) process?
That is, if the modification is a replacement-in-kind can we forego a PSSR? Possibly, but remember that if the
replacement includes welding, the work performed may justify using the PSSR process to insure that no new
hazards have been introduced. In a way, this type of PSSR is more of a checklist prior to re-introducing
ammonia into the evacuated portion of the system.

Once a revision, alteration, addition, or removal has been identified as a change triggering a PSSR, the PSM
standard requires the PSSR process to assure that all the proper documentation, procedures, and training are in
place prior to reintroducing ammonia into the system.

1910.119(i)(2): The pre-startup safety review shall confirm that prior to the
introduction of highly hazardous chemicals to a process:
(i) Construction and equipment is in accordance with design
specifications;
(ii) Safety, operating, maintenance, and emergency procedures
are in place and are adequate;
(iii) For new facilities, a process hazard analysis has been
performed and recommendations have been resolved or
implemented before startup; and modified facilities meet
the requirements contained in management of change,
1910.119(l).
(iv) Training of each employee involved in operating a
process has been completed.

Reviewing this section of the PSM Standard makes it pretty clear that the PSSR element is all about ensuring
that the MOC requirements have been performed. To maintain quality control, consider requiring the
signatures for the PSSR to be independent of those for the MOC. It is also clear that the scope of the PSSR
spans from design and construction to the completion of updates to other PSM elements for the covered
process. Specifically, the PSM elements potentially affected include: process safety information, operating
procedures, training, and process hazard analysis. Clearly, PSSR is not something “tacked on” at the end of a
project but, rather, should be started at the beginning and remain open throughout the life of a project.

COMMON PROBLEMS WITH PSSR

PSSR not done before project start-up
Apart from not being compliant with the requirements of the PSM standard, not performing (or completing) a
PSSR prior to the introduction of ammonia to the system creates risk. A corollary would just say that a plant not
consistently doing PSSRs when required is a plant that has a malfunctioning PSM program. As such, when a
PSM audit is done, the activity level of MOCs and PSSRs at a plant is a great indicator as to whether or not PSM
is alive at a plant.

PSSR not done by competent personnel

Who should be responsible for PSSR? What constitutes competence? Ideally, a PSSR should not be executed by
the same person responsible for the MOC. Table 1 shows some possible reviewers for portions of the PSSR.
You may not have all of these personnel at your plant, so what types of personnel are suited to conduct a PSSR?
Ideally, whatever their title, the signatory would be independent, knowledgeable of the process/technology,
and understand the value of the PSSR process. Without the last characteristic though, the other two won’t
really matter. A person seeing PSSR as a “paper exercise” or an unnecessary roadblock to getting the project
started will most likely not execute the PSSR as OSHA intended, nor in a manner that will deliver the benefits
this QA process can offer.

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Table 1: Typical personnel to review and approve changes.

Personnel Reviewing/Approving Nature of Change

PSM Coordinator None (ideally)

Maintenance supervisor Operating procedures

Process safety information, MOC,

Engineering manager
Design/construction specifications

Safety director/representative Training

Purchasing representative Receipt of specified materials

Plant manager MOC

Corporate engineer PHA

PSSR done using out-dated documents

In order for the PSSR to be properly performed, all of the documentation needs to be current and “as-built.”
Considering that part of the PSSR is to assure that the process safety information (PSI) is complete and up-to-
date, using out-to-date Piping & Instrument Diagrams (P&IDs) to guide any field verification that might be
required during the PSSR is completely inappropriate.

Construction documents not used as the basis of the PSSR

The scope of PSSR clearly indicates that it includes design aspects of the project. Not utilizing any
documentation from the project construction is definitely a problem.

PSSR TRIGGERS
What commonly triggers a PSSR? It shouldn’t surprise you that the triggers are going to be similar to those
projects that trigger a MOC; however, PSSR may include activities that are not explicitly covered by a MOC.
Remember that every MOC will require a change in the PSI and that changing the PSI falls within the scope of a
PSSR (1910.119(i)(1)).

As a reminder from our newsletter article on MOC, examples of revisions that should trigger a MOC:

“closeout of PHA recommendations, addressing incident investigation recommendations, correcting

compliance audit exceptions; and operational upset responses (e.g. false alarms). Another obvious
trigger would be the addition of a new production line within a plant or the expansion of production
capacity or refrigerated storage. Software or programming changes to refrigeration and related controls
is another MOC trigger. New or revised contractor service agreements should be managed using the
MOC process. Changes to the budget for maintenance on covered process equipment should trigger a
MOC. Finally, any revisions to refrigeration-related staffing need to be managed under the MOC
process. This could be changes that include force reduction (both in terms of staffing numbers and/or
experience), shift changes or coverage changes. The latter items are often made without regard to how
they impact the covered process because they inadvertently bypass the MOC process.” See Reindl
(2009) for additional examples of MOC triggers.”

But are there other situations that should trigger a PSSR? What about a replacement-in-kind that requires a
significant part of the system to be isolated, evacuated and worked on during the replacement? What about a
large or coordinated, but infrequent, maintenance activity? What about recovering from an emergency
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shutdown? Does it make any sense that these activities should these also trigger a PSSR? YES!

RISK BASED PSSR

If this all sounds a bit daunting, it doesn’t need to be. CCPS [2007] recommends different level PSSR forms for
different levels of risk. From a simple checklist to the use of the team, the scope of the project or activity should
dictate the depth of a PSSR. The larger the project or the more risk a project presents, the more intensive the
PSSR needs to be in order to minimize the risk. Below is an example risk matrix with two (2) questions: What is
the likelihood of an event?, and What is the severity of the event?

For the lower (green) risk activities, a short form could be used. For all others, a longer, more detailed, form
should be used. It is important to realize that a shorter form does not mean that the PSSR is less important, just
a lower level of sign-off and effort. The longer form will necessarily have more review and sign-off.

There may be other indicators that a long form PSSR is needed as well. Consider the following as triggers for a
longer PSSR:
• Project cost greater than $X (where the cost threshold is tied to corporate capital request rules)
• New type of equipment or chemicals (first application on site)
• Three (3) or more piping tie-in points
• New control systems or modification to controls that could affect safety controls or interlocks
• Fire protection system changes
• Reuse of used or previously mothballed equipment
• Modifications to or deployment of critical safety systems

RECOMMENDATIONS FOR PSSR

The biggest recommendation for PSSR is to verify its function as part of your PSM program. In general, any
synergies and streamlining that can done to make the process more successful will benefit not only the PSSR, but

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the covered system as well. Integration of the PSSR into the MOC process is one potential; however, the two
elements need to be able to be separated when audited. And speaking of auditing, when any part of PSM is
audited and it is discovered that the element is not being done, don’t stop there. Look for the barriers and try
to eliminate them to make the program more effective. Ask the whys. Why are people bypassing the element?
Is the form too complicated? Can we simplify it?

Require more than just a single signature. Ask the signatory to list the documents reviewed including the
revision number or date.

Develop a short- and long-form PSSR. And maybe one step farther, create and use checklists for other parts of
the PSM process or maintenance procedures focused on the quality assurance aspect of PSSR. Examples could
be documentation of on-the-job-training (OJT) or operating procedure revalidation.

CONCLUSION
The PSSR element of the PSM standard is frequently misunderstood and infrequently or inconsistently utilized.
As a result, many plants see PSSR as an unnecessary step in the life of the project. Think back to past projects,
were there issues uncovered in the start-up that could have been caught and dealt with prior that would have
benefited the start-up? Think about the quality assurance programs that your plant uses elsewhere in your
processes, can those be transported and molded into an effective PSSR program for your ammonia refrigeration
systems? We encourage you to use the concepts presented in the issue of the Cold Front to review your
entire PSSR program and make appropriate revisions and updates to improve its function within your overall
PSM program.

REFERENCES
CCPS, Guidelines for Performing Effective Pre-Startup Safety Reviews, Center for Chemical Process Safety, New
York, NY, (2007).

OSHA, “Process safety management of highly hazardous chemicals”, U.S. Occupational Safety and Health
Administration, 29 CFR 1910.119, (1992).

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Refrigerant Inventory Management

Web courses!
Held via the web October 29, 2010 at 8-10 am Central or November 29, 2010 at 1-3 pm
Central, this workshop is an ideal opportunity to develop or improve your understanding of refrigerant
inventory estimation and management. All industrial refrigeration system end-users need to develop
estimates of the inventory of refrigerant in their systems and continually update the estimates as
changes are made to their systems.

This workshop is a perfect opportunity for you or your staff to review the basic principles of inventory
calculations. In addition, participate and see how the IRC’s online Charge Management Tool can
facilitate your efforts in developing and managing your refrigerant inventory calculations.

This workshop has been designed especially for those who want a better understanding of the principles
& practices of inventory calculations. This workshop will exceed the expectations of plant PSM
coordinators, plant and corporate engineering staff, refrigeration system operators, and refrigeration
supervisory staff with responsibilities that include PSM.

Each attendee will receive an electronic copy of hand-out materials as well as a copy of the IRC’s
TechNote entitled Refrigerant Inventory Determination. In addition, the IRC has developed a web-based
Charge Management tool. Non-members receive access to the IRC’s Charge Management Tool for 24
months. The tool features:

 Graphical user interface to describe & estimate inventory in most system components
 Ability to separate the system into areas
 One-click reports for easy printing

Access to the tool is provided free of charge to those completing this course. A brochure for the course
is available by clicking here.

Non-members: $395 per person (includes 24 months of tool access)

IRC Members: No cost!

There are two (2) ways to enroll in the course. First, individuals can enroll using our website at:
http://www.irc.wisc.edu/?/conf_registration (we accept payment via MasterCard & Visa). Second,
individuals can simply fill out the last page on the attached brochure and fax it to the IRC at (608) 262-
6209.

Please let us know if you have any questions on the course or the tool by e-mailing info@irc.wisc.edu.

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Relief System Design Web course!

Held via the web December 6-10, 2010 at 8-10 am Central, this workshop is an ideal opportunity to
develop or improve your understanding of engineered safety relief systems. Our primary focus is
industrial refrigeration systems but many of the principles we will discuss apply equally to other
applications as well.
Whether you are an end-user, equipment manufacturer, design engineer, or contractor, this course will
help you build your capabilities in the area of the principles and practices of engineering safety relief
systems. Participate and develop your understanding of:

 Codes and Standards related to safety relief systems

 Key aspects of engineering code-compliant relief systems
 Capacity determination for non-standard equipment like heat exchangers
 Methods for proper sizing of relief vent piping, including headered vent systems

In addition to the course, the IRC has developed a web-based safety relief systems analysis tool. This
powerful tool has a high degree of flexibility to analyze, engineer, and document safety relief systems
for industrial refrigeration applications. The tool features:

 Graphical user interface to configure relief system to be analyzed

 Ability to handle headered systems & multiple relief scenarios
 Quick and accurate algorithm to solve compressible flow equations
 Relief valve selection wizard
 Equivalent lengths for elbows & fittings included
 Detailed compliance checks for each system component
 One-click reports for easy printing

Access to the tool is provided free of charge to those completing this course. A brochure for the course
is available by clicking here.

The deadline for enrollment is Friday, December 3. There are two (2) ways to enroll in the course.
First, individuals can enroll using our website at: http://www.irc.wisc.edu/?/conf_registration (we accept
payment via MasterCard & Visa). Second, individuals can simply fill out the last page on the attached
brochure and fax it to the IRC at (608) 262-6209. We are also offering non-members an opportunity to
purchase the companion Engineering Safety Relief Systems guidebook.

Please let us know if you have any questions on the course, the tool, or the guidebook by e-mailing
info@irc.wisc.edu.