In a recent poll, we posed the question to process safety management (PSM) professionals: “What triggers a Pre-Startup Safety Review (PSSR) for an existing facility?”
The responses varied:
57% believed a PSSR is triggered “When a MOC is initiated.”
22% indicated it occurs “When equipment changes.”
13% chose “When procedures change.”
9% selected “When the PSI changes.”
While the responses reflect common assumptions in PSM practices, the correct trigger, according to the regulations, may not be as intuitive. Let’s explore the specifics and clear up any confusion surrounding PSSR requirements.
The Role of an MOC
Many respondents selected "When a Management of Change (MOC) is initiated," and that’s a logical assumption. A MOC is used to evaluate and manage changes in a facility’s processes, equipment, or procedures that could impact safety. Naturally, if a change is significant enough to warrant an MOC, it’s easy to assume a PSSR would follow.
However, according to the regulation, an MOC alone does not officially trigger a PSSR. While an MOC is a good indicator that a review might be needed, it’s not the direct trigger.
What the Regulation Actually Says (Title 40 CFR §68.77(a))
The requirement under Title 40 CFR §68.77(a) specifies that a PSSR must be performed when there is a modification significant enough to require a change in the Process Safety Information (PSI). This means that if the change impacts the key safety data of the process, such as chemical properties, equipment design specs, or operating procedures, a PSSR is
required.
The Distinction:
MOC = A process for evaluating and managing changes.
PSI change = The actual trigger for a PSSR, indicating that the change is significant enough to affect the fundamental safety information of the process.
In many situations, an MOC will indeed lead to updates in the PSI, and when that happens, a PSSR is required. But it’s important to understand that it’s the change in PSI, not the MOC
itself, that triggers the PSSR.
Why This Matters
Understanding this distinction is helpful for understanding when a PSSR is required to be initiated. While initiating an MOC is a critical part of managing changes in a facility, recognizing that a PSSR is only required when there’s a significant change to the PSI helps align practices with regulatory standards outlined in Title 40 CFR §68.77.
By staying clear on the true trigger for a PSSR, facilities can maintain safety and regulatory compliance, while avoiding unnecessary steps.
Interesting information. I am humored by your polling numbers that adds up to 101%.