It is important that a safety review takes place before any highly hazardous chemical is introduced into a process. PSM, therefore, requires the employer to perform 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. Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety review must confirm the following:
 

  • Construction and equipment are in accordance with design specifications

  • Safety, operating, maintenance, and emergency procedures are in place and are adequate

  • A process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements

  • Training of each employee involved in operating a process has been completed