It appears that the 7.4 Pre-Start-up Safety Review checklists are in addition to OSHA’s PSM PSSR. The pre-charging review is required to occur before the new or modified process is charged with ammonia, very much in line with the OSHA PSSR. You should compare the list with your PSM PSSR checklist to assure that all items listed in Appendix D are included in your PSM program. The 7.3 Pre-Charging Safety Review checklists in Appendix D are generic in content and do not include all the items required in the OSHA PSSR. One is essentially the same as the OSHA PSSR and the other is more like mechanical integrity. These two paragraphs require that two reviews be undertaken for new or modified facilities. Some Pre-Start-up Check List items are listed in Appendix D. Prior to starting the system for the first time, a Pre-Start-up Check List shall be completed. 119, Process Safety Management of Highly Hazardous Chemicals (ref.
All Pre-charging Check List items shall be confirmed in accordance with OSHA regulation. An example of a Pre-charging Check List is provided in Appendix D. Prior to charging refrigeration grade ammonia (see 5.1) into the refrigeration system, the designated start-up technician shall confirm that personnel and equipment are ready. The specific language in IIAR-5 reads as follows:
Are IIAR-5 checklists and reviews the same thing? Do the IIAR-5 checklists replace the PSSR documentation already part of your PSM program? Or are they in addition to your program? OSHA 1910.119’s Pre-Startup Safety Review (PSSR) has always been a requirement for new or modified processes. Since the requirements come from an industry standard, you should consider them as RAGAGEP and therefore mandatory.
One of the requirements that came with the release of ANSI/IIAR-5 2013 was that of Pre-Charging and Pre-Start-Up Review checklists.
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