Pre-Startup Safety Review (PSSR) Template
Four-page pre-startup safety review for ONE new or modified facility or unit: the review record linked to the management of change record, reviewers, 40 checks in eight groups (construction and equipment per design, safety systems, safety, operating, maintenance and emergency procedures, process hazard analysis and its recommendations, training, management of change requirements, P&ID and document updates, pre-startup conditions) each answered Yes, No or N/A with an evidence reference, an open items table with owner, due date and whether each item blocks start-up, a start-up decision with who authorised it and a check of their independence (the form's own rule), and sign-off. Its checks follow the matters listed in 29 CFR 1910.119(i) (not reviewed by OSHA); that rule, 40 CFR 68.77 and the British COMAH Regulations apply only to some processes. It is not a management of change record, a permit to work or a safety device bypass record.
What's inside
Page 1: the review and who did it
- Review record: PSSR reference, facility or unit, PSSR lead, planned start-up date, change or project reference (the management of change record number), project or turnaround number, date the review was held, scope of the change (new facility, modified facility, restart after turnaround, replacement in kind), what is changing and why, and the hazardous chemicals to be introduced with quantity and entry point
- Reviewers: name, role, the check groups each one covered and whether they were independent of the design and construction
Pages 2 and 3: the checks, each Yes, No or N/A with an evidence reference
- Forty check rows in eight groups: A construction and equipment per design (8), B safety systems (7), C safety, operating, maintenance and emergency procedures in place (5), D process hazard analysis and recommendations (3), E training and personnel (5), F management of change requirements met (4), G P&ID and documents updated (3), H pre-startup conditions (5)
- Open items: item and check number, owner, due date, whether it blocks start-up, whether the risk was accepted and by whom, status
Page 4: decision and sign-off
- Start-up decision: authorised, authorised with conditions, or not authorised; a tally of the 40 rows; blocking items raised and closed; conditions; who authorised, when, and when chemicals were first introduced; the independence of the authoriser (the form's own rule)
- Sign-off: PSSR lead, operations lead, process engineer, HSE representative, maintenance lead and the site manager giving final approval, each with name, signature and date
The group titles, the rows and the tick boxes are ours, to change. The checks follow the matters listed in 29 CFR 1910.119(i) (not reviewed by OSHA); the blocks-start-up column and the independence rule are the form's own and are marked as such on the form.
What requires or shapes this record
A pre-startup safety review is a named requirement in two US process safety rules with almost the same wording, and the matters it lists are the core of most company procedures. These rules cover only some processes. OSHA's standard applies to a process with a listed chemical at or above a threshold quantity, or with a flammable gas or liquid in a quantity above a stated amount, and its paragraph (a) lists exclusions that include oil or gas well drilling or servicing operations and normally unoccupied remote facilities. EPA's rule applies to a stationary source with more than a threshold quantity of a regulated substance, and its pre-startup review sits in the Program 3 requirements. In Great Britain the COMAH Regulations 2015 apply where dangerous substances reach the thresholds in Schedule 1, and HSE's guidance for assessors describes commissioning checks in general terms. Outside those regimes, and in other countries, whether you need a formal review before start-up depends on the process and on the law that applies to you; CCOHS in Canada describes the same idea as revalidating hazards, risks and controls when a process is new or changed. None of the sources opened for this page prescribes this form, asks for a particular layout or says who must authorise start-up, and a completed form does not show compliance with any law or standard. The blocks-start-up column, the independence rule for the authoriser and the single tally are this form's own. This page is general information, not legal advice.
- 29 CFR 1910.119(a), (b), (e)(5), (h), (i), (l) and nonmandatory Appendix C paragraph 8 (US OSHA); text read through the eCFR, current to 16 October 2026
US rule that applies only to processes within its scope. Paragraph (a)(1) covers a process involving a listed chemical at or above the threshold quantity in appendix A, and a process with a Category 1 flammable gas or a flammable liquid with a flashpoint below 100 degrees F on site in one location in a quantity of 10,000 pounds or more, with exceptions; (a)(2) says it does not apply to retail facilities, oil or gas well drilling or servicing operations, or normally unoccupied remote facilities. Paragraph (i)(1) requires a pre-startup safety 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 confirms, before highly hazardous chemicals are introduced to a process, 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, and that a modified facility meets the management of change requirements of paragraph (l); and that training of each employee involved in operating a process has been completed. Paragraph (l)(3) to (l)(5) require affected employees to be informed of and trained in a change before start-up and the process safety information and operating procedures to be updated. Paragraph (e)(5) requires a system to resolve PHA recommendations in a timely manner and to document the resolution. Paragraph (h)(2) and (h)(3) say how an employer treats contractors (evaluating their safety performance, informing them of hazards and the emergency action plan) and require the contract employer to train each contract employee and document it; the standard does not use the term 'PSM-qualified'. Appendix C is a nonmandatory guideline, not a requirement; its paragraph 8 says that for a new process the P&IDs are to be completed, the operating procedures in place and the operating staff trained before startup, that initial startup procedures are evaluated as part of the review, and that incident investigation, compliance audit and PHA recommendations are reviewed for their effect before startup. The standard does not require a particular form, a sign-off, an independent authoriser or a blocking list. The standard's own text is not reproduced here.
- 40 CFR 68.77 and 68.10 (US EPA); text read through the eCFR, current to 16 October 2026
EPA's Risk Management Program rule has a pre-startup review in section 68.77 with near-identical wording to the OSHA paragraph, using 'stationary sources' and 'regulated substances': it is required for new stationary sources and for modified ones when the modification is significant enough to require a change in the process safety information, and it confirms construction and equipment per design specifications, procedures in place and adequate, for a new source a process hazard analysis with recommendations resolved or implemented before startup (and for a modified one the management of change requirements of section 68.75), and completed operator training. The section sits in subpart D, the Program 3 prevention program. Section 68.10 sets the thresholds and says which program applies: paragraph (l) makes a covered process subject to Program 3 where it is in certain NAICS codes or is subject to OSHA's 29 CFR 1910.119. Read the rule itself, including its scope and the Program 1 and Program 2 conditions, before relying on this summary.
- HSE (Great Britain), COMAH technical measures: Operating procedures and Plant modification / change procedures, and the COMAH 2015 introduction page
HSE publishes these pages as Technical Measures Documents on its COMAH site, tied to the criteria the Competent Authority uses; they are guidance, not a requirement, and set no form. The operating procedures page says commissioning is the practical test of the adequacy of earlier preparations, including training and operating instructions; that safety precautions for commissioning should be reviewed as part of the HAZOP or risk assessment; and that full written operating instructions should be provided for all commissioning activities. It lists a typical commissioning sequence (system configuration check, verification of instrument alarms and trips, flushing and cleaning with water, assessment of ancillary equipment, calibration, a start-up protocol, chemical trials and handover) and says the checklist serves as a permanent record that can be reviewed if later modifications are made. It also lists start-up hazards, for example furnaces, dryers and vessels that rely on inert gas purging to keep oxygen out. The plant modification page (https://www.hse.gov.uk/comah/sragtech/techmeasplantmod.htm) says modifications should be designed, constructed, inspected, tested and proved to have achieved the design intent, that a proposal for change is formally authorised after technical investigation by competent personnel of senior status, and that one stage of a staged HAZOP is a check that all intended actions have been implemented, including hardware and software, with a pre-commissioning check. A paragraph it cites from an HSE ammonia storage guide asks for a competent person to authorise returning plant to service after modification; it says nothing about independence. The COMAH 2015 page (https://www.hse.gov.uk/comah/comah15.htm) says the regulations mainly affect the chemical industry and also some storage, explosives and nuclear sites and other industries where threshold quantities of the dangerous substances in Schedule 1 are kept or used, and that regulation 3 with Schedule 1 shows whether they apply to you and at which tier.
- CCOHS (Canada), OSH Answers fact sheet Process Safety Management (first published and last revised 13 December 2023)
Canadian general guidance, not a statement of any jurisdiction's legal duties. The fact sheet says that when new processes are introduced or a process is changed, hazards, risks and control measures need to be revalidated, and that after changes the hazards and risks need to be identified and assessed again and the control measures revalidated, with the controls modified if needed. It lists methods such as process hazard analysis and HAZOP and names the CSA standard Z767:17 Process Safety Management (title only; the standard's text is not reproduced or described here). It does not describe a pre-startup review form.
Each source checked on 20 October 2026. Not legal advice; check the text in force for your site.
Field by field
Every field below is a printed label on the form. The form has 40 check rows in eight groups, lettered A to H, and the row numbers (A1, A2 and so on) are what the open items table points back to. Rows A1, C1 to C4, D1, D2, E1 and F1 follow the four matters paragraph (i) of the US standard says the review confirms; F2, F3 and G3 follow the change rules in paragraph (l); D3 follows nonmandatory guidance in Appendix C. Every other row is practice carried over from an earlier checklist or added by this form. The form supplies no oxygen limit, test pressure, set point, deadline or tolerable risk: you write the value and its source.
- Facility or unit
- Why: One review covers one facility or unit and one change, so the checks, the open items and the decision can be tied to a single piece of plant.
- Common mistake: Reviewing a whole site in one form, so nobody can tell which unit an open item or an authorisation belongs to.
- Change or project reference
- Why: Links the review to the management of change record that approved the change; the US rule asks that a modified facility meet the management of change requirements before start-up. A turnaround or project number is a second link.
- Common mistake: Leaving it blank because the work was 'just a project', then finding no record of the technical basis, the approvals or the training that the review is meant to confirm.
- Scope of the change
- Why: The US rule requires a review for new facilities and for modified ones when the modification is significant enough to change the process safety information; a replacement in kind that satisfies the design specification is outside management of change. The box makes someone state which applies.
- Common mistake: Calling a modification a replacement in kind because it is quicker, when the design specification is not the same.
- Reviewers
- Why: Shows who looked at what and whether they were independent of the design and construction, so a signature can be read as 'I checked groups C and E'.
- Common mistake: Listing only the people who signed, or having the people who built the plant be the only reviewers.
- Construction and equipment per design
- Why: First matter in paragraph (i)(2): construction and equipment are in accordance with design specifications. Eight rows keep the walk-down, testing, relief devices and instruments each answerable.
- Common mistake: Answering Yes from the construction handover pack without a walk-down, so a temporary support, blind or jumper stays in the line.
- Safety systems
- Why: Detection, shutdown, safety instrumented functions, fire protection and emergency equipment are the protection that must work when the first chemicals are introduced. These rows come from the earlier checklist.
- Common mistake: Ticking Yes for a trip that was tested alone but not end to end through the cause-and-effect matrix.
- Safety, operating, maintenance and emergency procedures in place
- Why: Second matter in paragraph (i)(2): the procedures are in place and adequate. HSE adds that commissioning needs full written instructions and that start-up is the practical test of the earlier preparations.
- Common mistake: Counting a draft procedure as in place, or forgetting the maintenance procedure and the start-up steps.
- Process hazard analysis and recommendations
- Why: Third matter in paragraph (i)(2): for a new facility a process hazard analysis has been performed and its recommendations resolved or implemented before startup; the US rule also requires the resolution to be documented.
- Common mistake: Moving a recommendation to 'tracked' so start-up can go ahead, without a written reason or an owner, and without checking whether your rules allow it.
- Training and personnel
- Why: Fourth matter in paragraph (i)(2): operator training is complete. The form adds maintenance staff, contract employees, the briefing and shift handover, because a start-up often crosses a shift change.
- Common mistake: Treating a contractor as 'qualified' and recording no training, when the contract employer's own training record is what should be on file.
- Management of change requirements met
- Why: Modified facilities must meet the management of change requirements before start-up: the change approved first, affected people informed and trained, and the actions closed or accepted with a recorded basis.
- Common mistake: Closing the MOC record on paper while its actions are still open, or never having raised one.
- P&ID and documents updated
- Why: The US rule requires the process safety information and operating procedures to be updated when a change alters them. Drawings that do not match the plant are the root of most later mistakes.
- Common mistake: Marking up a working copy of a P&ID that is never approved or issued.
- Pre-startup conditions
- Why: The last physical checks before material goes in: housekeeping, blinds, inerting or purging, utilities and closed permits. These rows come from the earlier checklist; HSE lists inert gas purging among start-up hazards.
- Common mistake: Writing an oxygen limit from memory instead of from the procedure, or leaving a hot work permit open while the line is being filled.
- Evidence reference
- Why: A Yes with no pointer cannot be checked later. The reference (certificate number, loop sheet, minutes, permit number) lets someone else find what the answer rested on.
- Common mistake: Writing 'done' or 'see file' instead of a document number and date.
- Open items
- Why: Every No and every action finished after start-up is written here with an owner, a due date and whether it blocks start-up. The US rule does not say what may stay open; the column is the form's own so the decision is made on a list rather than a feeling.
- Common mistake: Marking an item as not blocking because the owner is busy, or accepting risk with no named person.
- Start-up decision
- Why: One recorded decision, with its conditions, who made it and when, and when chemicals were first introduced, so the order of events can be shown. The US standard says what the review confirms, not who decides.
- Common mistake: Authorising before the blocking items are closed and 'tidying up' the paperwork afterwards.
- Independence of the authoriser
- Why: The form's own rule: the person who authorises start-up is not the PSSR lead, not the requester of the change and not the owner of the schedule or cost, because those people have a reason to want the start-up to go ahead. Neither the US text nor HSE's pages opened for this page require it.
- Common mistake: The project manager, who is also under pressure on the schedule, signing as 'site manager' because nobody else is on site.
- Sign-off
- Why: Each signature says the signer checked the groups written against their name and agrees with the answers and the open items; the site manager's line is the final approval.
- Common mistake: Signing for another function, or signing a blank form to speed the walk-round.
Worked example
IllustrativeNew inlet separator tied into a gas gathering station (invented plant)
| Section | Entry |
|---|---|
| Review record | PSSR-2026-014. Gas gathering station, inlet area. Change reference MOC-2026-031 (project P-212). Scope: modified facility, a new inlet separator tied into the existing inlet header, so the process safety information changes. Raised by the project engineer. Review held 12 November; planned start-up 16 November. Chemicals to be introduced: natural gas and condensate through the new tie-in. Lead: the process engineer. |
| Reviewers | Process engineer (groups A, C, D, G), operations supervisor (C, E, H), maintenance supervisor (A, B, C), HSE adviser (B, D, F), instrument technician (A, B). The HSE adviser and the instrument technician did not design or build the separator. |
| Checks | 40 rows: 33 Yes + 4 No + 3 N/A = 40. N/A with reasons: A6 (no rotating equipment in this change), E3 (no contractors on the start-up), F4 (an MOC was raised). The 4 No answers: A8 (loop check of level transmitter LT-201 not signed), D2 (one PHA recommendation, a second high-level alarm, not yet in service), C3 (maintenance procedure for the new drain valves not issued), G1 (P&ID mark-up not yet approved). |
| Open items | 5 items: (1) A8 loop check, owner instrument technician, due 13 November, blocks start-up. (2) D2 second high-level alarm, owner process engineer, due 13 November, blocks start-up. (3) G1 P&ID approval, owner project engineer, due 14 November, blocks start-up. (4) C3 maintenance procedure, owner maintenance supervisor, due 30 November, does not block; risk accepted by the site manager. (5) Tag labels on six valves, from the A2 walk-down punch list, owner operations supervisor, due 23 November, does not block. |
| Start-up decision | Authorised with conditions at 14:00 on 15 November by the site manager. 3 blocking items raised, 3 closed (items 1 and 2 on 13 November, item 3 on 14 November), closure checked by the instrument supervisor, not the owners. Every row answered. Conditions: items 4 and 5 are closed by 30 and 23 November. Gas first introduced at 06:30 on 16 November, after the planned start. |
| Independence of the authoriser | All three boxes ticked: the site manager did not lead the review (the process engineer did), did not raise the change (the project engineer did) and does not own the project schedule or cost (the project manager does). No second authoriser needed. |
| Sign-off | Six lines signed on 15 November: PSSR lead, operations lead, process engineer, HSE representative, maintenance lead and the site manager as final approval. |
The dates add up: the blocking items close on 13 and 14 November, before the decision on 15 November and the start-up on 16 November. 33 + 4 + 3 = 40 rows; 4 No answers plus 1 punch-list item make 5 open items, 3 that block and 2 that do not. Whether the C3 item may stay open past start-up is a decision for the site's own procedure and the rules that apply to it, not something the form grants.
When a spreadsheet stops being enough
Paper and spreadsheet reviews break in a predictable place: a No in the checks is copied to an action list by hand and later disagrees with it, and the evidence reference points to a file that has moved. Nothing stops an authoriser signing while an item that blocks start-up is still open.
A software record can keep each check with its evidence attached, copy every No into the open items automatically, refuse the start-up decision while a row is blank or a blocking item is open, refuse an authoriser who led the review or raised the change, and show non-blocking items that have passed their due date. It can also open the review from the management of change record it belongs to and show the permits still open on the unit.
In a demo, ask to see a review refused because one blocking item is open, an item changed from non-blocking to blocking after the decision and what the history then shows, and a reviewer replaced part-way through. Ask also whether the checks can be edited to your own procedure without losing the history of earlier reviews.
Same rule for every product: tagged “Process Safety”, “Barrier Management”, “Risk Management”, “Risk Assessment”, “Control of Work”, “Permit to Work” or “Asset Integrity”, with a sourced process safety (PHA, barrier or 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.
Tekmon pays for a sponsored placement (above); its place in this list follows the same rule as every entry. How lists are ordered
Haz360 · PHA study templates · Documented
Vendor source · Profile checked
BowTieXP · Bowtie scenario authoring and visualization · Documented
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Onspring · Risk register and mitigation management · Documented
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Prometheus Group · Mechanical-integrity inspection records · Documented
Vendor source · Profile checked
Sphera Control of Work · Barrier and deviation visibility · Documented
Vendor source · Profile checked
VisiumKMS · Management of change with pre-startup safety review · Documented
Vendor source · Profile checked
Intelex · Management of change workflow · Documented
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Synergi Life (DNV) · Bow-tie and barriers · Documented
Vendor source · Profile checked
Tekmon · Process Safety Management (vendor-stated) · Vendor-stated, not yet publicly confirmed
Ask to see it in a demo · Profile checked
Cority · Management of change workflow · Documented
Vendor source · Profile checked
Enablon · Process hazard analysis · Conditional
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Evotix · Enterprise management of change · Documented
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IsoMetrix · Shared risk libraries · Documented
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Origami Risk · Process-safety and chemical-management scope · Conditional
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SAP Environment, Health, and Safety · Management-of-change risk handoff · Conditional
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Sphera · PHA-Pro process hazard analysis and HAZOP · Documented
Vendor source · Profile checked
Accupoint · Process safety bundle (OSHA PSM) · Documented
Vendor source · Profile checked
BizzMine · Hazardous substances, work permits, management of change and lockout tagout · Conditional
Vendor source · Profile checked
CORE-EHS · Bow-tie barrier management · Documented
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FirstPriority · Dual Assurance critical control monitoring · Documented
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Optial · Management of change · Documented
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SMS360 · Actions, management of change, claims and document library · Conditional
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TenForce · Further modules listed (change, documents, risk, quality, contractor, environment) · Conditional
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All 23 matching profiles are shown. Documentation review, not hands-on testing or a claim of compliance.