ELEMENT OVERVIEW
Ensuring the safe startup of processes over the life of a facility is one of nine elements in the RBPS pillar of managing risk. This chapter describes the management practices for performing pre-startup reviews of (1) new processes, (2) processes that have been shut down for modification, and (3) processes that have been administratively shut down for other reasons. These practices verify the operational readiness (readiness) of a process and help to ensure that the process is safe to restart. Section 16.2 describes the key principles and essential features of a management system for this element. Section 16.3 lists work activities that support these essential features and presents a range of approaches that might be appropriate for each work activity, depending on perceived risk, resources, and organizational culture. Sections 16.4 through 16.6 include (1) ideas for improving the effectiveness of management systems and specific programs that support this element, (2) metrics that could be used to monitor this element, and (3) management review issues that may be appropriate for readiness.
What Is It?
The readiness element ensures that shut down processes are verified to be in a safe condition for re-start. This element addresses startups from all types of shut down conditions and considers the length of time the process was in the shut down condition. Some processes may be shut down only briefly, while others may have undergone a lengthy maintenance/modification outage, or they may even have been mothballed for an extended period. Other processes may have been shut down for administrative reasons, such as a lack of product demand; for reasons unrelated to production at all; or as a precautionary measure, for example, because of an approaching hurricane. In addition to the shutdown duration, this element considers the type of work that may have been conducted on the process (e.g., possibly involving line-breaking) during the shutdown period to help focus the readiness review prior to startup. The readiness element in these Guidelines is defined more broadly than the OSHA process safety management pre-startup safety review element in that it specifically addresses startup from all shutdown conditions – not only those resulting from new or changed processes (Refs. 16.1 and 16.2).
Why Is It Important?
Experience has shown that the frequency of incidents is higher during process transitions such as startups. These incidents have often resulted from the physical process conditions not being exactly as they were intended for safe operation. Thus, it is important that the process status be verified as safe to start.
Where/When Is It Done?
Readiness reviews are conducted prior to startup on new processes, and on existing processes that were shut down for any reason. A review involves some or all of the following concerns and activities: (1) confirming that the construction and equipment of a process are in accordance with design specifications, (2) ensuring that adequate safety, operating, maintenance, and emergency procedures are in place, and (3) ensuring that training has been completed for all workers who may affect the process. Also, for new processes, it confirms that an appropriate risk analysis has been performed, and that any recommendations have been resolved and implemented. Modified processes should have undergone a management of change (MOC) review. For all startups (including those after minor, short-term shutdowns not involving any changes), readiness reviews ensure that the process is safe to be released to operations by examining issues such as the equipment lineup, leak tightness, proper isolation from other systems not yet ready for startup, and cleanliness.
Who Does It?
Simple readiness reviews may involve only one operator, maintenance person, or engineer. More complex startups, such as those for new units, entire plants, or a large unit after an extended shutdown, may involve many people, from all of the disciplines that are typically a part of a large capital project.
What Is the Anticipated Work Product?
The output of the readiness activity is either (1) an affirmation that the process is ready to safely start up and authorization to do so or (2) a list of actions that must be taken to make the process ready. Many times the readiness process and startup authorization is documented on a form, which creates an audit trail to ensure that all required actions have indeed been completed. For complex startup situations, reviewers may use several different checklists of information and necessary actions to confirm the status of all of the items reviewed. Outputs of the readiness element can also be used to facilitate the performance of other elements. For example, a walkdown of a process prior to startup can identify deficient equipment conditions that can provide input to the asset integrity element.
How Is It Done?
Readiness reviews of simple startups may involve only one person walking through the process to verify that nothing has changed and the equipment is ready to resume operation. Complex reviews may extend over many weeks or months as engineering, operations, and maintenance personnel verify equipment conformance to design intent, construction quality, procedure completion, training competency, and so forth. Typically, extensive checklists, multi-stage verification, and multiple functional sign-offs are required for startup authorization. Higher risk situations usually dictate a greater need for formality and for thoroughness in scope and level of detail; for example, greater detail in the checklists used to guide the evaluation. Less rigorous approaches, such as those using a simple checklist or no checklist at all, may be adequate for lower risk processes. Facilities whose operations are very dynamic may require readiness practices that are very flexible. Facilities with solid process safety cultures can often rely on more performance-based pre-startup tools, since a strong culture provides greater confidence that employees will check out the system thoroughly according to the designed startup procedure. However, in practice, those facilities with a sound process safety culture normally embrace the use of comprehensive checklists to guide and document readiness reviews. Facilities with an evolving or undetermined process safety culture may require more detailed, prescriptive approaches and tools to provide greater command and control management system features to ensure good performance.