Prepare for Pre-Startup Safety Review: PSM Element 7 Checklist

Author: Fidelis Associates | Published: 2026-03-03 | Last Updated: 2026-03-03

Meta Description: Checklist for OSHA 1910.119(i) Pre-Startup Safety Review — verify construction conformance, safety systems, procedures, PHA resolution, and training before startup.

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OSHA Reference

Under OSHA's Process Safety Management standard 29 CFR 1910.119(i), employers must perform a Pre-Startup Safety Review for new facilities and for modified facilities when the modification is significant enough to require a change in process safety information. The PSSR must confirm that: 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 requirements contained in management of change. Training of each employee involved in operating the process has been completed.

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Fidelis Insight

PSSR is the final verification gate before a process goes live. It exists to confirm that everything promised during design, construction, and planning has actually been delivered — in the field, not just on paper. When PSSRs are conducted thoroughly, they catch construction errors, incomplete punch lists, missing procedures, and unresolved PHA recommendations before they become operational hazards.

The challenge is that PSSRs often face schedule pressure. Projects are behind, commercial commitments are firm, and the pressure to "start up on time" can compress or shortcut the review. Strong PSSR programs resist this pressure by establishing clear hold points that cannot be bypassed, requiring field verification (not just document review), and ensuring that open items are either resolved or managed with formal interim controls before introducing hazardous materials.

PSSR connects directly to MOC, PHA, operating procedures, and training — it is the integration point where these elements must all come together before startup.

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Common Gaps We See

• ⚠ PSSRs conducted as document reviews without field verification
• ⚠ Open items from PHA recommendations or punch lists carried into live operations without interim controls
• ⚠ Schedule pressure compresses PSSR scope or bypasses hold points
• ⚠ PSSR triggered for new facilities but missed for modifications that change PSI
• ⚠ Safety systems verified on paper but not functionally tested
• ⚠ Training completion not verified before startup authorization
• ⚠ PSSR scope doesn't include verification of operating and emergency procedures
• ⚠ No clear link between MOC close-out and PSSR requirements

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Best Practices Checklist

Construction & Equipment

• [ ] Construction and equipment verified in accordance with design specifications
• [ ] Punch list items resolved or managed with documented interim controls
• [ ] P&IDs reflect as-built conditions including field modifications
• [ ] Instrumentation calibrated and verified against design requirements

Safety Systems

• [ ] Safety, relief, and emergency shutdown systems installed and functional
• [ ] Interlocks, alarms, and detection systems tested and verified
• [ ] Fire protection and suppression systems operational
• [ ] Emergency equipment (eyewash, showers, PPE) in place and accessible

Procedures & Documentation

• [ ] Operating procedures in place, adequate, and accessible to operators
• [ ] Maintenance and inspection procedures established for new or modified equipment
• [ ] Emergency procedures updated to reflect new or modified process conditions
• [ ] Process safety information updated to reflect as-built conditions

PHA & MOC

• [ ] PHA completed for new facilities with recommendations resolved before startup
• [ ] MOC requirements satisfied for modified facilities
• [ ] PHA recommendations for modifications addressed or formally deferred with interim controls
• [ ] Documentation demonstrates compliance with MOC close-out requirements

Training & Readiness

• [ ] Training completed for each employee involved in operating the process
• [ ] Training covers new or modified procedures, hazards, and equipment
• [ ] Competency verified — not just attendance documented
• [ ] Contractor personnel trained on relevant changes

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Scoring Tip

• 17–20 checks = Strong PSSR program
• 10–16 checks = Needs improvement
• 0–9 checks = Immediate action required

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Practical Use

Use this checklist before every startup of a new or modified facility. Treat PSSR as a mandatory hold point, not a formality. Walk down the field to verify that construction matches design, safety systems are functional, and operators are trained and ready. Open items must be formally resolved or managed — "we'll fix it after startup" is not an acceptable disposition for safety-critical items.

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Key Takeaways

• PSSR is the final gate before hazardous materials are introduced — it must be thorough, not rushed.
• Field verification is essential — paper reviews alone miss construction errors and incomplete work.
• Open PHA recommendations must be resolved or have documented interim controls before startup.
• PSSR applies to modifications that change PSI, not just new facilities.
• Training completion is a PSSR requirement — untrained personnel cannot be authorized for startup.

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Assess Your Program

Use this checklist as a starting point, then benchmark your program with a FidelisCheck PSM assessment.

Start Free PSM Assessment →

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Related Resources

• What is Process Safety Management? A Complete Guide
• The 14 Elements of PSM: A Practitioner's Breakdown
• OSHA 1910.119 PSM Compliance Checklist
• What is a Pre-Startup Safety Review (PSSR)?
• PSSR Preparation Checklist: What to Verify Before Startup

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Frequently Asked Questions

When is a pre-startup safety review required? OSHA 29 CFR 1910.119(i) requires a PSSR for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. This means any MOC that alters process chemistry, equipment design, operating limits, or safety systems should trigger a PSSR. The key trigger is whether the change necessitates an update to PSI. Routine maintenance that restores equipment to its original design specification generally does not require a PSSR, but any change that alters the process or its safeguards does.

What must a PSSR confirm before startup? Under 1910.119(i)(2), the PSSR must confirm four things: construction and equipment are in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; a PHA has been performed for new facilities and recommendations resolved or implemented before startup; and modified facilities meet the requirements of management of change, including updated training for each employee involved in operating the process. The PSSR is a verification activity, not a planning activity. It confirms that work already committed to during design and MOC has actually been completed.

Do like-for-like equipment replacements require a PSSR? OSHA does not explicitly exempt like-for-like replacements from PSSR requirements. The determining factor under 1910.119(i) is whether the replacement requires a change to process safety information. A true like-for-like replacement that restores equipment to its original design specification, using the same materials of construction, design pressure, and configuration, typically does not require a PSSR because no PSI change is involved. However, if the replacement differs in any way from the original design, materials, or capacity, it constitutes a change that requires MOC and a corresponding PSSR. Best practice is to document the basis for determining whether a replacement is truly like-for-like.

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Fidelis Associates provides PSM compliance consulting and assessment services through FidelisCore and FidelisGap. Our team brings 40+ years of combined experience across major operators including Chevron, Valero, and Shell.

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