PSSRPre-Startup Safety Review
Pre-Startup Safety Review — a readiness review before a new or sufficiently modified process starts, as the US OSHA process safety rule requires.
Editorial definition: The QHSE Standard, updated 3 October 2026 · https://qhsetech.com/glossary/pssr
Scope: For US OSHA PSM, the modification trigger relates to a change significant enough to require updated process-safety information.
Sources checked: . Examples are editorial illustrations.
What OSHA's process safety rule says about a pre-startup safety review
In this glossary PSSR means pre-startup safety review, a requirement of the US process safety management standard, 29 CFR 1910.119(i), which covers processes involving highly hazardous chemicals within its scope. Paragraph (i)(1) requires a review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Paragraph (i)(2) says the review must confirm four things before highly hazardous chemicals are introduced: that construction and equipment are in accordance with design specifications; that safety, operating, maintenance and emergency procedures are in place and adequate; that, for a new facility, a process hazard analysis has been performed and its recommendations resolved or implemented before startup, while for a modified facility the management of change requirements of paragraph (l) are met; and that training of each employee involved in operating the process has been completed.
An OSHA letter of interpretation of 1996 addresses the trigger. OSHA said it did not intend a review for each facility modified slightly. It treats a facility as modified when it is connected to or dependent on an existing one, and as new when it is physically separated from and independent of existing facilities. The letter raises a spare pump piped in parallel and an additional storage tank as questions and gives the connected-or-independent test rather than a ruling on each, so the answer depends on the facts. For changes beyond replacement in kind, the letter says the management of change standard applies, and it notes that process hazard analyses may be needed more often when an existing facility is modified more than slightly.
The same letters stand for something else in Great Britain. The Pressure Systems Safety Regulations 2000 (SI 2000/128) are also abbreviated PSSR, and they concern pressure systems: their regulations cover safe operating limits, a written scheme of examination, examination in accordance with it, maintenance, modification and repair, and the keeping of records. That is a different instrument with different duties, so a record or search that mixes the two will mislead. This page deals with the pre-startup review and is general information, not legal advice. Whether 1910.119 applies to a process depends on the substances and quantities it covers.
Sources opened :
- OSHA: 29 CFR 1910.119, process safety management of highly hazardous chemicals (paragraph (i)) (opens in a new tab)
- OSHA: letter of interpretation on the scope of pre-startup reviews (1996) (opens in a new tab)
- legislation.gov.uk: Pressure Systems Safety Regulations 2000 (SI 2000/128), contents (opens in a new tab)
What a pre-startup review record holds in software
- The trigger: a new facility or a modification, with the change reference and the reasoning on whether the change was significant enough to need updated process safety information.
- A checklist of the four confirmations (construction against design, procedures, hazard analysis or change requirements, training), each with a result, a date and an owner.
- Open items from the review, with a decision on whether each must close before startup.
- Links to the process hazard analysis or management of change record the review relies on, with their status.
- Training completion for the operators, by person and by process.
- The decision to start up, with the approver and the date.
PSSR the review, PSSR the regulations and management of change
The pre-startup safety review is the last check before a process starts, while management of change is the procedure that decides whether and how a change is made, and a modified facility must meet its requirements before startup. The Pressure Systems Safety Regulations 2000 share the abbreviation but are a separate Great Britain regime about pressure equipment.
A hypothetical example: a spare pump and a separate unit
This scenario is invented and describes no real facility. A plant that handles a covered chemical adds a spare pump in parallel with an existing transfer pump and separately plans a small package unit on the far side of the site, physically separated from existing facilities and independent of them. For each change the engineer records whether the process safety information has to change and whether the facility is modified or new, citing the 1996 interpretation in the record.
For the pump, the change record shows a modification that needs updated piping information, so a review is opened. The reviewer checks the installation against the revised design, confirms that the operating and maintenance procedures name the new pump, confirms that the change management steps are closed, and finds that two operators have not completed training. The training item stays open and startup is held until both completions are recorded. For the independent unit, the record shows a new facility, so the review also confirms that its hazard analysis recommendations are resolved before startup.
Common misunderstandings about the pre-startup review
- PSSR is not a certificate or a form number. Paragraph (i) describes what the review has to confirm.
- Not every change triggers a review. OSHA said it did not intend one for each slight modification, and the trigger is a change significant enough to require updated process safety information.
- A new unit and a modified unit are checked differently. A new facility needs its hazard analysis recommendations resolved, while a modified facility needs the management of change requirements met.
- Training is part of the review and not a later step. Completion for each employee involved in operating the process is one of the four confirmations.
- The abbreviation is shared. In Great Britain the Pressure Systems Safety Regulations 2000 are also abbreviated PSSR, and they are a separate instrument.
How PSSR relates to other glossary terms
The review is the point where several process safety records meet before startup.
- PSM: the standard that contains the pre-startup review and the other elements around it.
- PHA: the hazard analysis that a new facility must have performed, with its recommendations resolved, before startup.
- MOC: the procedure whose requirements a modified facility must meet before startup.
- SOP: the written operating procedures whose adequacy the review confirms.
Records and evidence that usually exist for a pre-startup review
- The change or new-facility record that triggered the review.
- The completed review with the four confirmations.
- The process safety information as updated for the change.
- The hazard analysis and its resolved recommendations, or the change management record.
- Training records for the employees who operate the process.
- The record of open items and when each closed.
What a software tool needs to capture for a pre-startup review
- A link between the change record and the review it opens.
- A checklist of the four confirmations that a reviewer completes and signs with dates.
- A hold status that blocks the ready-for-startup step while an item is open.
- Links to the hazard analysis, procedures and training records, not copies of them.
- A field for new or modified facility, with the reasoning on significance.
- A way to keep this term apart from pressure systems records on sites that hold both.
- Version history for each review.
Catalog profiles documenting management-of-change workflows
The list follows the management-of-change rule. It does not show that a product holds a pre-startup review checklist, which should be tested, because a change record is not itself a review.
Same rule for every product: tagged “Management of Change”, with a sourced management-of-change capability in its record, or one the vendor stated to us, labelled as vendor-stated. Documented and conditional capabilities qualify; check the linked scope before treating a module as included.
Ordered by how closely our sources document this process, not by quality. Sponsored placements are labelled. How lists are ordered
Intelex · Management of change workflow · Documented
Vendor source · Profile checked
Cority · Management of change workflow · Documented
Vendor source · Profile checked
ERA-EHS · Management of change and PSSR · Documented
Vendor source · Profile checked
Evotix · Enterprise management of change · Documented
Vendor source · Profile checked
Safework Suite · Management of change · Documented
Vendor source · Profile checked
Sphera · Management of change review · Documented
Vendor source · Profile checked
Optial · Management of change · Documented
Vendor source · Profile checked
SMS360 · Actions, management of change, claims and document library · Conditional
Vendor source · Profile checked
TenForce · Further modules listed (change, documents, risk, quality, contractor, environment) · Conditional
Vendor source · Profile checked
VisiumKMS · Management of change with pre-startup safety review · Documented
Vendor source · Profile checked
All 10 matching profiles are shown. Documentation review, not hands-on testing or a claim of compliance.
Related software
Frequently asked questions
Is a pre-startup safety review required for every change?
Under paragraph (i)(1) it is required for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. OSHA's 1996 letter said it did not intend a review for every slightly modified facility.
What must the review confirm?
Paragraph (i)(2) lists four confirmations: construction and equipment match the design specifications, the procedures are in place and adequate, the hazard analysis (new facilities) or the management of change requirements (modified facilities) are met, and operating employees are trained.
Is PSSR the same as the Pressure Systems Safety Regulations?
No. The abbreviation is shared. The Pressure Systems Safety Regulations 2000 are a Great Britain instrument on pressure systems, with duties such as a written scheme of examination, and are separate from the US pre-startup review.
More safety terms
Related guides
- US OSHA 2026: Electronic Recordkeeping and PSM Changes
Article on US OSHA recordkeeping and PSM changes.
- Management of Change (MOC) Template
Free template for a management of change request.
- EU Seveso III Compliance Guide for Major-Hazard Sites (2026)
Article on EU Seveso III compliance for major-hazard sites.