SEMS Element #9 – Pre-Startup Review

Most companies I have dealt with will have all of these items individually addressed in their SEMS. I will explain a few 30 CFR 250.1917 problem areas I have found to be repeated by a few of my clients.

§ 250.1917 What criteria for pre-startup review must be in my SEMS program?

Your SEMS program must require that the commissioning process include a pre-startup safety and environmental review for new and significantly modified facilities that are subject to this subpart to confirm that the following criteria are met:

a)       Construction and equipment are in accordance with applicable specifications.

b)       Safety, environmental, operating, maintenance, and emergency procedures are in place and are adequate.

c)       Safety and environmental information is current.

d)       Hazards analysis recommendations have been implemented as appropriate.

e)       Training of operating personnel has been completed.

f)        Programs to address management of change and other elements of this subpart are in place.

g)       Safe work practices are in place.

Most companies will have it implied that a Pre-Startup review must take place. However, a surprising number of them do not officially have a pre-startup review policy/ procedure in place. One item I have seen them fall short is when it comes to the pre-startup procedures related to safety system function testing requirements. This must be performed prior to putting the item in service. The need for this procedure should be identified in your hazard analysis related to putting the equipment in service and should therefore be addressed in a procedure.

Don’t forget that the safety system function testing will have to comply with a SAFE chart or some other type of document. The SAFE chart, for example, will let you know what should happen when each component is tested. If the action required isn’t initiated, then that device has just failed. Worst case scenario is a malfunction calls for a facility or component shut-in which doesn’t occur. And of course, document the entire process. If it isn’t documented, then it didn’t happen. Don’t forget 30 CFR 250.1916(d):

§ 250.1916 What criteria for mechanical integrity must my SEMS program meet?

These procedures must address the following:

(d) The documentation of each inspection and test that has been performed on your equipment and systems. This documentation must identify the date of the inspection or test; include the name and position, and the signature of the person who performed the inspection or test; include the serial number or other identifier of the equipment on which the inspection or test was performed; include a description of the inspection or test performed; and the results of the inspection test.

This will not only put you in compliance, but may well prevent a bunch of downtime from occurring because a brand new or, as is the case many times, reconditioned component fails.

If you are changing like kind equipment, then the process is very straight forward as the existing safety, environmental, operating, maintenance and emergency procedures will be the same as what you are already using. However, if the equipment doesn’t have the same operating parameters or is a different manufacturer, then you will have to re-evaluate everything.

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