PSSR Preparation Checklist: What to Verify Before Startup

Author: Fidelis Associates | Published: 2026-03-02 | Last Updated: 2026-03-02

Meta Description: A Pre-Startup Safety Review (PSSR) preparation checklist covering construction verification, safety system testing, procedure reviews, training completion, and regulatory readiness.

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Definition / Introduction

This checklist is a practical preparation tool for the Pre-Startup Safety Review (PSSR) required by OSHA under 29 CFR 1910.119(i). PSSR is the final verification gate before introducing highly hazardous chemicals into new or modified facilities. It is not a formality — it is the last structured opportunity to identify and resolve safety gaps before a process goes live.

This checklist is organized by PSSR verification area and is intended for PSM coordinators, startup leads, operations managers, and PSSR facilitators. Use it to prepare for the PSSR itself, verify that prerequisite work is complete, and identify open items that must be resolved before hazardous materials are introduced.

For a comprehensive guide to PSSR requirements, triggers, and best practices, see What is a Pre-Startup Safety Review (PSSR)?.

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Construction Completeness

• [ ] Physical installation matches approved design drawings (P&IDs, isometrics, general arrangement drawings)
• [ ] As-built redlines have been incorporated into official documentation — field modifications during construction are captured
• [ ] Equipment is properly tagged and identifiable per the design numbering system
• [ ] Materials of construction match specifications, with material test reports available for critical equipment
• [ ] Piping pressure tests (hydrostatic or pneumatic) are complete with documented results
• [ ] Insulation, fireproofing, and corrosion protection are installed per specification
• [ ] Structural steel, platforms, and access ways are complete and meet safety standards (guardrails, toe boards, ladder cages)

Safety System Verification

• [ ] Safety instrumented systems (SIS) have been function-tested end-to-end, including final elements (valves, trips, shutdowns)
• [ ] Cause-and-effect matrix testing is complete — every initiating condition produces the correct protective action
• [ ] Emergency shutdown (ESD) systems operate as designed from initiation to final element closure
• [ ] Fire and gas detection systems are calibrated, operational, and integrated with alarm and shutdown logic
• [ ] Pressure relief devices are installed with correct set pressures and discharge routing
• [ ] Relief device inlet and outlet block valves are in the correct position (locked/car-sealed open per design)
• [ ] Safety system bypasses and overrides are documented, with criteria for removal before startup

Procedures and Documentation

• [ ] Operating procedures cover all phases: initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following turnaround
• [ ] Procedures are specific to the process being started — not generic templates
• [ ] Procedures address safe operating limits and consequences of deviation
• [ ] Maintenance procedures are in place for critical equipment and safety-critical instruments
• [ ] Emergency procedures address credible scenarios identified in the PHA
• [ ] All procedures are reviewed, approved, and accessible to the personnel who will use them
• [ ] Process safety information (PSI) is complete and reflects the as-built facility

Training and Competency

• [ ] All operators assigned to the process have completed initial training covering process overview, operating procedures, safety hazards, and emergency operations
• [ ] Training records document the employee, date of training, and means used to verify comprehension
• [ ] Competency verification demonstrates that operators understand — not just attended training
• [ ] Maintenance personnel are trained on equipment-specific maintenance and inspection procedures
• [ ] Contract workers performing PSM-covered activities have received appropriate process-specific hazard communication
• [ ] Refresher training is current for all personnel (at least every 3 years per OSHA requirements)

Equipment and Materials

• [ ] Rotating equipment (pumps, compressors, fans) has been run-tested with correct rotation, vibration, and performance verified
• [ ] Instrument loop checks are complete — every instrument reads correctly and communicates with the control system
• [ ] Control valves have been stroked through full range with correct action on signal failure
• [ ] Electrical systems are energized, ground fault tested, and motor control centers verified
• [ ] Lubrication systems are filled and circulated per vendor and design requirements
• [ ] Chemical and catalyst inventories are available on-site per the startup plan
• [ ] Temporary construction items (blinds, scaffolding, temporary piping) are removed or documented with status tracking

Process Hazard Analysis (PHA) Compliance

• [ ] The initial PHA for the new or modified process is complete
• [ ] All PHA recommendations relevant to the new or modified process have been resolved or formally addressed
• [ ] Open PHA items have documented interim risk controls if they cannot be closed before startup
• [ ] PHA revalidation is current (within the 5-year cycle) for existing processes that have been modified
• [ ] The PHA team included personnel knowledgeable in engineering, operations, and the specific process

Regulatory and Permit Readiness

• [ ] All required operating permits (air, water, waste discharge) are issued and effective
• [ ] OSHA PSM PSSR requirements under 1910.119(i) are satisfied with documented evidence
• [ ] For modified facilities: Management of Change (MOC) requirements under 1910.119(l) are satisfied
• [ ] Environmental monitoring systems are operational and capable of meeting permit conditions
• [ ] Local regulatory notifications (fire marshal, emergency management, environmental agency) are complete
• [ ] Insurance and risk management notifications have been made as required

PSSR Documentation and Sign-Off

• [ ] The PSSR scope is defined — which systems, processes, and modifications are covered by this review
• [ ] PSSR participants include operations, maintenance, engineering, safety, and management representatives
• [ ] All PSSR findings have an assigned owner, due date, and defined closure criteria
• [ ] Critical findings (must-resolve-before-startup) are distinguished from non-critical findings (post-startup resolution acceptable with risk assessment)
• [ ] Final PSSR authorization is signed by the designated authority — the person or role with explicit go/no-go authority for introducing hazardous materials
• [ ] PSSR documentation is filed and accessible for regulatory audits and future reference

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Key Takeaways

• PSSR is the last safety gate before hazardous materials enter the process. Treat it as a substantive safety evaluation, not a paperwork exercise.
• Construction completeness verification requires physical field walkdowns, not just document reviews.
• Safety system testing must be end-to-end, including final elements — function tests on logic alone are insufficient.
• Training completion means competency verification, not attendance records.
• Open PHA items must be resolved or formally risk-assessed with documented interim controls before startup authorization.

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Assess Your Program

Preparing for a PSSR and want to ensure your program meets OSHA requirements and industry best practices? Start with a free readiness assessment.

Start Free Readiness Assessment →

For expert-led PSSR facilitation, FidelisForce provides experienced professionals who have led PSSRs across refineries, chemical plants, hydrogen facilities, and greenfield startups.

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Related Resources

• What is a Pre-Startup Safety Review (PSSR)? — Comprehensive guide to PSSR requirements, common failures, and best practices.
• Operational Readiness Review (ORR) Checklist and Process — The broader readiness evaluation that complements PSSR.
• Commissioning, Startup & Operational Readiness: A Complete Guide — The pillar guide covering the full CSU lifecycle.
• The 14 Elements of PSM: A Practitioner's Breakdown — PSSR is one of the 14 PSM elements. Understand how it fits within the full PSM framework.

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Fidelis Associates provides PSSR facilitation and operational readiness services through FidelisForce and FidelisCore. Our team has facilitated PSSRs across hydrogen production facilities, environmental services operations, and major refining operations.

Schedule a Discovery Call → | Request PSSR Support →