Epic Fails: Now Who Was Supposed to Check That? Pre-Startup Safety Reviews

Bill Lape’s article discusses OSHA’s Process Safety Management (PSM) regulations, found in 29 CFR 1910.119, and EPA’s Chemical 2 RETA.com 21 Accident Prevention Provisions, or RMP, found in 40 CFR Part 68. Both contain sections pertaining to the conduct of Pre-Startup Safety Reviews (PSSR). Both regulations state, in essence, that when modifying a covered process, such as an ammonia refrigeration system, a PSSR is required when the change is significant enough to require a change to the Process Safety Information of the system.

The regulations go on to state that the PSSR will, prior to the introduction of ammonia into that section of the process, confirm that the construction (of the change) and the equipment (installed or modified during the change) have been in accordance with the design specifications. The regulations further state that adequate safety, operating, maintenance, and emergency procedures are in place.

Let Bill step you through regulatory compliance and Pre-Startup Safety Reviews.


Bill LapeAbout the Author: Bill Lape is a Project Director for SCS Engineers. He is a Certified Industrial Refrigeration Operator, Certified Refrigeration Service Technician, and a member of the National Board of Directors of the Refrigerating Engineers and Technicians Association. You may reach him at or on LinkedIn.


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