Restart and quality
Plant Start-Up After Shutdown: Restart Checks and PSSR
Before a plant restarts after a shutdown, someone with authority should confirm that equipment matches specification, procedures and training are in place, isolations are removed in order, known defects are cleared and the right people are in the unit. OSHA's pre-startup safety review formalizes the first of these checks for covered processes.
Restart is the second half of phase 4 in the five-phase model, followed by close-out and review.
How MaintWiz helps: Quality problems start when a package begins before it is ready. The MaintWiz shutdown module checks seven readiness gates before a package starts and records waivers with a typed reason, name and date. See the module · Get the readiness checklist
By Jai Balachandran · Published · Last reviewed
What MaintWiz adds:Seven readiness gatesSigned waivers with name and dateKeyboard operationLook-ahead by gate
The gate
What must be checked before a plant restarts after a shutdown?
Before a plant restarts, someone with authority should confirm that equipment is built and repaired to specification, procedures and training are in place, isolations are removed in order, known defects are cleared and the right people are in the unit. Under OSHA's process safety standard, a pre-startup safety review confirms the first items before hazardous chemicals are introduced. 1
The OSHA rules that bear on restart are mapped in OSHA PSM turnaround rules. Food plants add a sanitation release: food and beverage plant shutdowns. A free Excel file for this page: restart readiness checklist (US and UK) (.xlsx). The restart gate is one of the seven gates in turnaround readiness review and phase gates.
| Check | Evidence | Signs off | Basis |
|---|---|---|---|
| Equipment built and repaired to specification; changes reviewed | Inspection and test records; management of change records | Engineering and operations | OSHA PSSR confirmation OSHA 1910.119 |
| Procedures in place and adequate; people trained | Updated start-up procedure; training records | Operations manager | OSHA PSSR confirmation OSHA 1910.119 |
| Isolations removed in the planned order; blanks reconciled | Isolation certificates closed; blank and blind register balanced | Operations and permit authority | HSE HSG253 |
| Disturbed joints, leak tests and valve positions confirmed | Joint control and leak-test records; valve position check against the plan | Operations | HSE HSG253 |
| No isolation tags left; system checked against the P&ID | Visual walk-down by operations personnel | Operations | HSE HSG253 |
| Known instrument and alarm defects cleared | Calibration and function test records | Instrument lead | BP Texas City: started despite reported malfunctions CSB Texas City report |
| Staffing and supervision for the start-up period | Roster showing extra operators and knowledgeable supervisors present in hazardous phases | Plant manager | CSB Texas City recommendations CSB |
| Nonessential people kept out while hazardous material is reintroduced | Exclusion zone defined and communicated | Operations and safety | CSB Kuraray report |
| Return to use approved after maintenance (sterile manufacturing) | Qualification and approval record | Quality unit | EU GMP Annex 1, EU GMP Annex 15 |
The sign-off column is a working template; assign roles to match your site. The evidence column follows the cited guidance where a basis is shown.
PSSR
What is a pre-startup safety review?
A pre-startup safety review (PSSR) is a check, required by OSHA for covered processes, that construction and equipment match design, procedures are in place and adequate, any change has been reviewed and training is complete before hazardous chemicals are introduced. 1
The shutdown turnaround glossary lists both meanings of PSSR; the UK meaning is explained in PSSR pressure systems safety regulations in the UK. The UK pressure systems rules are explained in PSSR pressure systems safety regulations.
OSHA's paragraph applies to new facilities and to modified facilities when the modification requires a change in process safety information. 1 A routine shutdown with replacements in kind may not trigger it, but many sites run a restart review anyway because the same questions apply. Where the standard does not apply, the checks above are good practice, not a legal requirement.
Software
Can software support restart checks?
Software can hold the restart checklist, the test records and the sign-offs with the work orders they depend on, so open items are visible before the start-up decision.
Readiness gates are described in the shutdown management software overview.
About MaintWiz. MaintWiz is an industrial AI platform with IoT, SAP integration and predictive maintenance (PdM) capabilities. Its shutdown and turnaround module helps plants plan, schedule, execute and close out shutdown work.
Also: product data sheet.
What the shutdown module covers
As described on the MaintWiz shutdown maintenance product page.
- Shutdown calendar and critical-path scheduling, with work order sequencing and dependencies
- Asset prioritization, so the most critical equipment is scoped first
- Resource planning for people, spares, heavy equipment such as cranes, and outsourced vendors
- Electronic permits to work, risk management and contingency plans
- Real-time progress monitoring: schedule adherence, cost variance, quality metrics and risk factors
- Step-by-step checklists, pre-restart testing protocols and post-shutdown analysis
Proof
What MaintWiz customers report
Figures as published in MaintWiz case studies on maintwiz.com. They come from maintenance management projects, not shutdowns.
Quality plan
What is an inspection and test plan for a shutdown?
An inspection and test plan lists each quality-critical activity with its acceptance standard, the point where work stops for inspection, who signs and what record is kept, so that defects are found before the restart and not after it.
| Activity | Acceptance standard | Check point | Who signs | Record |
|---|---|---|---|---|
| Reassemble heat exchanger | Drawing and torque specification | Hold point before closing | Mechanical supervisor and inspector | Torque sheet |
| Pressure or leak test | Test procedure and pressure | Witness point | Inspector and operations | Test certificate |
| Align rotating equipment | Manufacturer tolerance | Witness point | Mechanical lead | Alignment report |
| Instrument loop check | Loop sheet | Hold point before start-up | Instrument lead and operations | Loop check record |
| Final walk-down | P&ID and punch list | Hold point before release | Operations | Signed walk-down |
The plan format is a working template; no public standard is cited here. Use your site's quality procedure where one exists. Quality in the wider shutdown is part of the five-phase model in the pillar guide.
Why it goes wrong
Why do problems appear right after a shutdown?
Public investigations point to four recurring causes: defects carried into the start-up, incomplete reinstatement, procedures that do not match the plant, and people in the wrong place when hazardous material returns. There is no published statistic on early-life failure rates after shutdowns, so this page gives none. 3,2,5
For UK pressure systems and isolation rules see HSG253 safe isolation for shutdowns. Tests before restart are planned in hydrotest and leak test planning.
Known defects carried over
At Texas City the unit was started despite previously reported malfunctions of the tower level indicator, a level sight glass and a pressure control valve. 3
Incomplete reinstatement
HSE lists a blank and blind register, control of disturbed joints, leak-test records and a visual check against the P&ID among the systems that assure full reinstatement. 2
Procedures that do not match the plant
The CSB recommended that start-up procedures be updated to reflect actual process conditions, and that knowledgeable supervisors be present in hazardous phases such as start-up. 4
People in the wrong place
In the Kuraray startup after a turnaround, welding by nonessential contractors likely ignited an ethylene release; no formal exclusion zone had been set. 5
The CSB's Husky Superior report also shows that the shutdown can be as hazardous as the restart: most safeguards that keep air and hydrocarbons apart during an FCC unit shutdown were not implemented or not effective. 6 See shutdown safety plan for the full picture.
Handback
How does restart connect to the rest of the shutdown?
Restart is the second half of phase 4, and it starts with the controlled hand back described in shutdown execution, then continues through the checks here and ends with the close-out review in shutdown lessons learned.
For GMP restart rules in pharmaceutical plants, see pharmaceutical plant shutdowns.
Readiness for restart should be planned from the start: the tests, the people and the approvals are part of the schedule in shutdown scheduling, not an afterthought.
Visuals
Save the restart charts
Both charts open full size when clicked, ready for the start-up meeting.
FAQ
Frequently asked questions
What should be checked before restarting a plant after a shutdown?
Equipment built and repaired to specification, procedures and training in place, isolations removed in order, known defects cleared and the right people in the unit. OSHA's pre-startup safety review covers the first group for covered processes. 1,2
What is a PSSR?
A pre-startup safety review: confirmation, before hazardous chemicals are introduced, that construction and equipment match design, procedures are adequate, changes were reviewed and training is complete. 1
Is a PSSR required after every shutdown?
OSHA's paragraph applies to new facilities and to modified facilities where the modification requires a change in process safety information, so a routine shutdown with replacements in kind may not trigger it. Many sites review anyway. 1
How do you assure full reinstatement after isolation?
HSE lists a blank and blind register, control of disturbed joints, purging records, leak testing records and a visual valve and tag check against the P&ID. 2
Why do breakdowns happen right after a shutdown?
Public investigations point to known defects carried into start-up, incomplete reinstatement, procedures that do not match the plant and people in the wrong place. There is no published failure-rate statistic. 3,2,5
Who should be present during a hazardous start-up?
The CSB recommended extra operator staffing and knowledgeable supervisors during start-up, and the Kuraray report found nonessential workers should be excluded when hazardous material is reintroduced. 4,5
What applies to restart in pharmaceutical plants?
EU GMP Annex 1 says return to use after maintenance should be approved, and Annex 15 says to use quality risk management to plan any requalification. 7,8
What is an inspection and test plan?
A list of quality-critical activities with the acceptance standard, hold or witness point, who signs and the record kept. The format on this page is a working template.
Sources
Sources
- OSHA, 29 CFR 1910.119, Process safety management of highly hazardous chemicals
- UK Health and Safety Executive, The safe isolation of plant and equipment (HSG253, 2006)
- US Chemical Safety and Hazard Investigation Board, Investigation Report: Refinery Explosion and Fire, BP Texas City (Report No. 2005-04-I-TX)
- U.S. Chemical Safety and Hazard Investigation Board, BP America (Texas City) refinery explosion
- US Chemical Safety and Hazard Investigation Board, Ethylene Release and Fire at Kuraray America, Inc. EVAL Plant, Pasadena, Texas (No. 2018-03-I-TX, 16 December 2022)
- US Chemical Safety and Hazard Investigation Board, FCC Unit Explosion and Asphalt Fire at Husky Superior Refinery (No. 2018-02-I-WI, 23 December 2022)
- European Commission, EU GMP Annex 1: Manufacture of Sterile Medicinal Products (2022)
- European Commission, EU GMP Annex 15: Qualification and Validation (2015)
Start each package only when it is ready
Book a demo and bring a work package. We will walk through the seven readiness gates.