Pa 020 0028 - PSSR
Pa 020 0028 - PSSR
1. PURPOSE
2. DEFINITIONS
2. DEFINITIONS cont’d
3. SCOPE
4. PROCEDURE
4.2. The PSSR can be categorized by the risk level assessment found in Tab 3 of the
MOC Change Manager database as determined either by the Risk Level
Assessment tool or Mode of Failure Analysis. Risk levels are defined in Section
2.4.
4. PROCEDURE cont’d
During the hazard review, the PSSR team scope should be identified. For
minor modifications (Level 1 (low or no risk)), a minimum of two people can
perform the PSSR. I n a l l c a s e s , t he PSSR team members must be
documented in Tab 6.
Please note that the PSSR Team Members list in Change Manager
incorrectly references long form use. This section should be used to
record team members for Short Form PSSRs as well.
In addition, the PSSR Long Form is required for all Capital Projects. For
Capital Projects, see the corporate procedure, Corporate Procedure
BC032.013 Ecology & Safety Project Reviews, for additional guidance.
“Short form” refers to the PSSR checklist that is built into tab 4 of the
Change Manager module. “Long form” refers to the Site PSSR Long Form
checklist (Attachment A). When the “Long form” is used, it must be attached to
the MOC in Tab 6 or file location referenced. The PSSR “Long Form” should be
modified (items added) to address the scope of the change as appropriate.
4. PROCEDURE cont’d
A. For Level 1 & 2 (Low & Medium) changes, the team will consist of a
minimum of two qualified personel approved by the Responsible
Manager or delegate.
B. For Level 3 & 4 (High & Critical) changes, the team will be made up of
a minimum of four representatives consisting of operations (both
exempt and non-exempt), subject matter expert(s) (exempt or non-
exempt), and safety. Other applicable departments including but not
limited to engineering, instrument, electrical, mechanical, and
operations management and/or process technician may be designated
by the area Responsible Manager.
4. PROCEDURE cont’d
C. For all capital engineering projects, the team will be made up of the
required team for the Level 3 & 4 change plus the project manager and
will follow the PSSR Long Form regardless of risk level.
4.6.3. The PSSR team should verify that all items marked as “Pre- Startup”
items, including those under “Items to complete prior to startup” on Tab
4 and the informing/training of employees as designated/documented in
Tab 5, has been completed or appropriately addressed. Additionally, the
team should verify that the technical basis for the proposed change has
been accurately documented on Tab 1, the impact of the change on
safety and health and the reviewers have been documented in Tab 3,
( i f a p p l i c a b l e ) the modifications to operating procedures and P&ID
redlines have been completed, and that the necessary time period for the
change has been documented (if temporary). Further, the team shall
verify the following:
Construction and equipment is in accordance with
design specifications;
Safety, operating, maintenance, and emergency procedures
are in place and are adequate;
For new facilities/stationary sources, a process hazard
analysis (which meets PSM/RMP regulatory expectations for
regulated facilities) has been performed and
recommendations have been resolved or implemented before
startup; and modified stationary sources meet the
requirements contained in management of change; and,
Training of each employee involved in operating a process
has been completed.
4.6.4. The PSSR Team shall assign the startup date and time on Tab 6. This
must be done before the MOC/PSSR can be sent to the final approvers.
If this date and time changes after final approval is given, it is the
responsibility of the Change Coordinator to update the date and time
as appropriate. Additionally, the Change Coordinator should verbally or
electronically notify all those trained/informed of the change of the
official date and startup change.
4. PROCEDURE cont’d
4.6.5. Once all open items designated as “pre-startup” items are complete, the
MOC is routed to the Unit Final Approver for approval to startup. This is
the final assurance that all “before startup” items planned have been
implemented, and that all process safety information, all operating
procedures, all training, and any other regulatory compliance
documentation has been properly updated or triggered to be updated.
4.8. Startup
Upon completion of all pre-startup action items, the MOC form is forwarded to the
Responsible Manager of the area for approval to implement and startup the
change.
4.10.1. The PSSR will be closed when all before and after start-up items are
completed.
4. PROCEDURE cont’d
4.10.3. The completed PSSR checklist shall be maintained with the matching
MOC for a minimum of five years or longer per BASF Record Retention
Requirements.
5. RESPONSIBILITIES
6. RELATED DOCUMENTS
Complete the PSSR Checklist after mechanical completion and prior to startup of facility.
Action Items should be entered in ACTION TRACKER database under appropriate section (Prior to or After Start-Up)
A. Pressure/Vacuum Consideration
Resp. Target
Item Y N N/A PS AS Action Needed Person Date
1. Has protection been provided against overpressure and
vacuum and is the correct size and setting relief device been
installed?
2. Is relief device discharge piping adequately braced
against reaction forces and directed away from personnel?
3. Have weep holes or drains been provided in the discharge
piping of pressure relief devices?
4. Have block valves been installed in relief device piping? If
YES are they full port valves and are they locked open?
5. Have new safety valves and rupture discs been tagged
and entered into the routine maintenance program?
6. Have provisions for cleaning relief device piping been
provided?
7. Have pressure relief device calculations been properly
documented and incorporated into the master relief device
records?
8. Have pressure relief devices been captured on safety
valve lock list?
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 9 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
B. Temperature/Reaction Considerations
Resp. Target
Item Y N N/A PS AS Action Needed Person Date
1. Have personnel been adequately protected from contact
with hot surfaces?
2. Has potential for instrument failure (including computer
shutdown) and loss of utilities been adequately
addressed?
3. Has potential for leaks into or out of the process been
adequately addressed?
4. Has potential for improper valve set-up or operating error
been adequately addressed?
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 10 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 11 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 12 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 13 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 14 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
G. Safety/Environmental Protection
Resp. Target
Item Y N N/A PS AS Action Needed Person Date
1. Have inert blankets, purges, sprinklers, and fire proofing
been installed where specified?
2. Has the installation created the need for relocating or
adding fire extinguishers, fire monitors, safety showers,
eye baths, or air packs?
3. Is the lighting adequate?
4. Have tripping hazards or head knockers been avoided?
5. Do walkways and ladders provide safe access at all
levels and are walking or working surfaces level,
properly secured, and do they provide proper traction?
Are safety gates properly installed?
6. Does equipment layout provide safe access for
operation and maintenance?
7. Have elevated work requirements been met?
8. Is the work area adequately ventilated where needed?
9. Are adequate provisions made for drum and cylinder
handling?
10. Has the HAZCOM program been updated to reflect
changes in chemicals? Are MSDS’s available?
11. Do signs adequately identify work area hazards and
provide proper instruction?
12. Are exit and egress routes clearly identified?
13. Have any new noise areas been created or existing
areas been made worse?
14. Has the system been reviewed to assure minimal
personnel exposure to toxic chemicals during operation
and maintenance?
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 15 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
H. Other Considerations
Resp. Target
Item Y N N/A PS AS Action Needed Person Date
1. Have all Management of Change items been completed
as required by the MOC Form?
2. Does the facility comply with all applicable engineering
standards and design specifications?
3. Were any safety problems created during construction
package?
4. Have operating procedures been written and operating
parameters established and has operator training been
conducted?
5. Have the safety and emergency procedures been
updated?
6. Has the potential impact of the change on unchanged
facilities been adequately addressed?
7. Has spare critical equipment been provided and set up in
the warehouse inventory?
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 16 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 17 of 18
Effective: 03/04/16 Approved By: EHS Manager
PA-020-0028 Attachment A
BASF TOTAL Petrochemicals LLC
I. Additional Considerations
Resp. Target
Item Y N N/A PS AS Action Needed Person Date
1.
2.
3.
4.
The Pre-Startup Safety Review is complete and this facility/modification is ready for startup upon completion of
all “PS” type deficiencies.
Inspection /PSSR Team: We agree that all PSSR questions and inspections were performed to the best of our ability.
Y = Yes, N = No, N/A = Not Applicable, PS = Prior to Start Up, AS = After Start Up Page 18 of 18
Effective: 03/04/16 Approved By: EHS Manager