How do you verify that PSSR recommendations are implemented and effective?

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Process safety management (PSM) is a systematic approach to prevent or mitigate hazardous incidents in industrial facilities that handle flammable, explosive, or toxic substances. One of the essential elements of PSM is the pre-startup safety review (PSSR), which is a check to ensure that the design, installation, operation, and maintenance of a new or modified process meet the safety standards and specifications. But how do you verify that the PSSR recommendations are implemented and effective? Here are some tips to help you conduct a thorough and reliable PSSR audit.

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Engage leadership on-site:

Leaders should actively visit sites to verify PSSR recommendations. This hands-on approach demonstrates commitment and encourages the entire organization to prioritize safety.### *Track and analyze data:Managers must gather data to measure the effectiveness of implemented recommendations. By proposing continuous improvements, they ensure ongoing compliance and safety enhancements.

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1 Define the scope and criteria

The first step is to define the scope and criteria of the PSSR audit, based on the nature, complexity, and risk level of the process. You should identify the applicable regulations, codes, standards, and best practices that govern the process safety, as well as the internal policies and procedures of your organization. You should also determine the objectives, scope, and frequency of the audit, as well as the roles and responsibilities of the audit team and the auditees.

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Rev. Michael Johnston

Senior Pastor at Carroll Springs Community Church
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As part of the PSSR, all findings of the PHA are required to be verified that all parts of the PHA have been implemented. Then the PSSR checklist is established and all elements checked off prior to startup.

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Farukh Ismailov

Logistics Safety Engineer @ NCOC N.V. | IOSH MS | Risk Management | HSE Competency Assurance | Compliance
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Consider the process's complexity, risks, and regulatory requirements. Identify relevant standards, internal policies, and objectives for the audit, including its frequency and roles. Clear definition sets the stage for a comprehensive assessment that enhances compliance, mitigates risks, and fosters continuous improvement in safety protocols. This structured approach ensures audits are effective, aligning organizational goals with industry best practices for optimal safety performance.

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2 Review the documentation and records

The next step is to review the documentation and records that provide evidence of the implementation and effectiveness of the PSSR recommendations. These may include the PSSR report, the management of change (MOC) documents, the process hazard analysis (PHA) reports, the operating procedures, the training records, the inspection and testing reports, the permits and licenses, and the incident reports. You should verify that the documentation and records are complete, accurate, consistent, and up to date, and that they comply with the relevant requirements and standards.

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Mo'men M.

Oil & Gas Senior EHS Specialist | Safety Engineer, Process Safety, Hazard Analysis NEBOSH PSM, IG, EMC, HSW, TechIOSH | Lead Auditor ISO 45001, 14001 IRCA Certified
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it’s evident that process safety hinges on the meticulous groundwork laid out in defining scope, criteria, and maintaining comprehensive documentation. Traditional insights remind us that "a house built on solid foundations withstands storms," emphasizing the importance of clarity and structure from the start. In the PSSR context, this means setting clear objectives, knowing the standards to uphold, and establishing responsibility among team members, which becomes the bedrock for a resilient safety culture.

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Farukh Ismailov

Logistics Safety Engineer @ NCOC N.V. | IOSH MS | Risk Management | HSE Competency Assurance | Compliance
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Assess PSSR reports, MOC documents, PHA reports, procedures, training, inspections, permits, and incident records. Verify completeness, accuracy, consistency, and compliance with standards. This ensures evidence-based decision-making, identifies gaps, and enhances process safety. Maintaining up-to-date and comprehensive documentation supports ongoing improvement, regulatory adherence, and operational resilience in managing risk effectively.

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3 Conduct interviews and observations

The third step is to conduct interviews and observations to verify the actual practices and conditions of the process. You should interview the key personnel involved in the PSSR, such as the project manager, the process engineer, the operator, the maintenance technician, and the safety specialist, to assess their knowledge, skills, and attitudes towards process safety. You should also observe the process equipment, piping, instrumentation, controls, and safeguards, to check their functionality, integrity, and suitability for the intended operation.

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Farukh Ismailov

Logistics Safety Engineer @ NCOC N.V. | IOSH MS | Risk Management | HSE Competency Assurance | Compliance
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Engage key personnel—project managers, engineers, operators, technicians, safety specialists—to assess their understanding and commitment to safety protocols. Observe equipment, piping, instrumentation, and controls to ensure functionality and integrity. This hands-on approach identifies discrepancies between documented procedures and actual practices, enabling corrective actions to enhance safety culture and operational reliability. Regular assessments foster a proactive environment that prioritizes continuous improvement and risk mitigation in industrial operations.

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4 Identify and report the findings

The fourth step is to identify and report the findings of the PSSR audit, which are the deviations from the expected or required performance or condition of the process. You should classify the findings according to their severity, impact, and urgency, and assign them to the responsible parties for corrective or preventive actions. You should also document the findings in a clear, concise, and factual manner, and communicate them to the relevant stakeholders.

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5 Follow up and close out

The final step is to follow up and close out the PSSR audit, which is the process of verifying that the findings are resolved and the actions are implemented and effective. You should monitor and track the progress and status of the actions, and provide feedback and support to the action owners. You should also conduct a verification or validation audit, if necessary, to confirm that the actions have achieved the desired results. You should then document and report the completion and closure of the PSSR audit, and update the PSM records and systems accordingly.

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Mo'men M.

Oil & Gas Senior EHS Specialist | Safety Engineer, Process Safety, Hazard Analysis NEBOSH PSM, IG, EMC, HSW, TechIOSH | Lead Auditor ISO 45001, 14001 IRCA Certified
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Interviewing key personnel and observing on-site conditions affirms that safety protocols are both understood and applied. Just as traditional artisans imparted skills through direct instruction and observation, interviews and hands-on checks help transfer and reinforce safety values among team members, building a safety-first mindset. This balanced approach of setting clear foundations, verifying rigorously, and engaging directly with stakeholders fosters continuous improvement and organizational resilience.

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Davien Bailey

Global Process Steward at Livent
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Something that has been very helpful for successful implementation of PSSRs is ensuring both on-shift and off-shift operators are trained on the scope and operation of the change as well as the critical process consequence mitigations (eg. Interlocks, DCS sequences, etc).

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6 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?

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Ir. Adam Maulana Musthafa, CFSP, CCPSC

Process Safety | HSE | Operations Integrity Management | Fire Protection
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How to verify that PSSR recommendations are implemented and effective? This should be very simple: 1) Leaders should trust the system but get their hands dirty to verify at site. Only when the leaders are showing that they care of what is happening at site (e.g., the implementation of PSSR Recommendation), will the organization collectively care about it. 2) Managers should gather the data and analyze to measure the effectiveness and propose a continuous improvement to the organization. 3) SMEs, focusing on higher risk item should also go and technically verify that the recommendations are implemented correctly 4) PSSR leaders or Plant managers should not proceed to sign start up certificate until the verification is conducted

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How do you verify that PSSR recommendations are implemented and effective?

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1 Define the scope and criteria

2 Review the documentation and records

3 Conduct interviews and observations

4 Identify and report the findings

5 Follow up and close out

6 Here’s what else to consider

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