The mechanical integrity program (MI) is a critical element of the Prevention Program component of OSHA’s Process Safety Management (PSM) and EPA’s Risk Management Program (RMP) implementations. Prevention Program elements are intended to prevent accidental releases of regulated substances through safety precautions, maintenance, monitoring, and employee measures at the source. As discussed in the Fall 2013 Environmental Quarterly article, preventive maintenance, inspection, and testing of equipment is critical to safe operations. Identification of the covered process boundary, the process hazard review, and process safety information will help identify equipment that is critical to safe operations. This information can then be used to develop the maintenance program. This article addresses the required elements of a maintenance program, including:
- Schedules for inspecting and testing equipment based on manufacturers’ recommendations, industry standards, recognized and generally accepted good engineering practices (RAGAGEP), and site experience
- Written maintenance procedures to maintain the mechanical integrity of process equipment
- Training for workers in the maintenance procedures
Inspection and Testing Schedules
Based on the established covered process boundary, the individual responsible for the Mechanical Integrity element should create a list of equipment and instrumentation subject to the PSM/RMP standards and establish equipment identification numbers or names that can be referenced in equipment repairs or inspections. For facilities that utilize an asset management system, this information is often already established for the entire site, and the facility can review the established asset system to identify PSM/RMP subject items. If the facility has detailed and current Piping and Instrumentation Diagrams (P&IDs) for the covered process, this can be an easy way to establish the boundary of covered equipment and to identify by equipment/valve/instrument number the items subject to the MI requirements.
NOTE: For facilities that have only portions of their process subject to PSM/RMP standards, some sites choose to manage all of their equipment under their MI system. While this is an advisable best practice, the site should clearly establish for which equipment these inspections are required so that internal or external auditing or enforcement efforts will be focused on only the subject equipment.
Once the list of subject equipment, valves, instrumentation, etc. has been identified and listed, the individual responsible for the Mechanical Integrity element must establish the required inspection and testing schedules for these items. Often it is useful to develop a spreadsheet or database of the PSM/RMP covered items at this point to assist in grouping common equipment types and listing the required frequency and inspection type for each item. There are many valuable sources of information available to review in establishing the inspection details:
- Original equipment manufacturer (OEM) information in the facility MI files often contain recommended frequency and type of inspections, critical spare parts, and recommended frequency of replacement of wear items. This is usually an excellent source of information for pumps, valves, ancillary equipment and instrumentation. If the OEM manual is not available in the files, contact the equipment manufacturer or representative for a current version of the OEM manual. For outdated or obsolete equipment, ask the equipment manufacturer or representative for inspection type and frequency recommendations based on similar current equipment.
- Original tank and vessel drawings will list the design code and version to which the equipment was built. The design codes often contain recommended inspection type and frequency and will reference or include the inspections and tests required after repairs to the unit.
- Equipment common to an industry or process may be covered under a specific code or regulation for that industry or use. Review applicable codes, standards, and regulations for information related to required or recommended system inspections and their frequency such as those published by:
- American National Standards Institute (ANSI)
- American Petroleum Institute (API)
- American Society of Mechanical Engineers (ASME)
- American Society for Testing and Materials (ASTM)
- National Fire Protection Association (NFPA)
- Chemical specific requirements codified in OSHA 1910.119 - Subpart H – Hazardous Materials – Sections 101 through 111
- Industry groups may prepare documents summarizing recommended inspections and their frequency for processes or equipment common to their industry.
- For facilities that have good equipment repair and inspection histories, the site can review and utilize their own maintenance history to establish recommended inspections and their frequency. If the facility is inspecting equipment on a basis less frequent than recommended by the manufacturer, the facility should document the basis for the reduced inspection frequency.
Once the inspection type and frequency matrix has been determined, the facility can establish the maintenance procedures and preventive maintenance work orders to implement the required inspections. In addition, the facility should review, perhaps annually, the established inspection type and frequency to determine if changes should be made based on inspection and breakdown work order results. This helps focus limited maintenance resources on the critical tasks and provides reassurance that the facility is utilizing its MI program information to prevent a catastrophic release.
Written Maintenance Procedures
While most facilities have established written operating procedures for their processes subject to PSM/RMP standards, the standards also require subject facilities to establish written maintenance procedures to inspect and maintain the mechanical integrity of the process equipment subject to the standards. These written maintenance procedures can be established in several forms:
- A facility can write general inspection procedures for each type of equipment (tanks, heat exchangers, pumps, piping, manual valves, actuated valves) and utilize or refer to these general inspection standards in the preventive maintenance inspections for their covered process;
- A facility can establish specific inspection procedures for each covered component and include or reference the specific procedure in the preventive maintenance inspections for that component;
- A facility can utilize a combination of general inspection procedures by equipment type along with equipment specific information added to the preventive maintenance inspection for subject equipment.
For preventive maintenance inspections and tests, the written maintenance procedures should list areas to inspect for signs of wear or misalignment, critical materials of construction (i.e., avoid potentially incompatible metals or gasket materials based on chemical use of that item), and parts that may be expected or planned to be replaced at each inspection interval. If the facility uses a maintenance management system and asset numbering, these instructions can often be included in the preventive maintenance work order that is established in the system for assets subject to PSM/RMP. This ensures that these critical details are automatically printed on the work order, making it easier for the maintenance employee to complete and document a thorough inspection. In addition, for facilities that have their maintenance management system integrated with a maintenance inventory management system, the facility can establish and link critical materials of construction for assets to minimize the potential for a spare part with incompatible materials to be checked out for use on covered equipment during repairs.
Training for Maintenance Employees
Once written maintenance procedures have been established, the facility must provide and document training of maintenance employees on these maintenance procedures. While it is common for maintenance employees to have significant experience, certifications and on-the-job training, the PSM/RMP standards require formal documented training on the established maintenance procedures. The site should establish a documented training plan for new maintenance employees which includes the maintenance procedures on covered processes. While the regulations do not require refresher training on maintenance procedures, it would be a best practice to consult maintenance employees and establish an effective refresher training frequency on the maintenance procedures.
Enforcement Focus on Mechanical Integrity
During recent inspections by EPA and OSHA, inspectors have focused on MI programs, especially on the methodology used to establish the types and frequencies of inspections and on confirming implementation of the Prevention Program elements like MI. In OSHA’s PSM Covered Chemical Facilities National Emphasis Program, effective November 29, 2011 (OSHA Directive CPL 03-00-014), OSHA stated “Based on inspection history at refineries and large chemical plants, OSHA has found that employers may have an extensive written process safety management program, but insufficient program implementation. Therefore, Compliance Safety and Health Officers should verify the implementation of PSM elements to ensure that the employer’s actual program is consistent with their written program.”
OSHA’s December 9, 2013 proposed revisions to the PSM Standard (78 FR 73576) included three items specifically impacting the MI element:
- Amending Paragraph (d) of the PSM Standard to require evaluation of updates to applicable Recognized And Generally Accepted Good Engineering Practices (RAGAGEP)
- Clarifying the PSM Standard by adding a definition for RAGAGEP
- Expanding the scope of Paragraph (j) of the PSM Standard to cover the mechanical integrity of any safety-critical equipment
Site maintenance and engineering resources are often stretched thin to complete “breakdown” repairs, identified facility and process improvements, and known preventive inspections, including MI inspections. Creation of the necessary MI inspection framework and justification requires a substantial time investment by subject sites and outside resources are often required in order to ensure a thorough and complete MI program is established. As demonstrated by recent enforcement decisions and penalties for deficiencies in MI programs at sites using anhydrous ammonia for refrigeration, EPA and OSHA continue to review MI programs in detail and expect companies to have complete inspection records of demonstrated reasoning for the type and frequency of MI inspections for their covered processes. Contact your local Trinity office for assistance with your site’s MI program.