Repair your mechanical integrity program

Many plants find it difficult to address a number of crucial issues.

By Michael J. Hazzan, Chemetica, Inc./AcuTech Consulting Group

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• containers used to transport PSM-covered materials via air, water, rail or ground, when they serve for temporary storage and are connected directly to a PSM-covered process, whether the container is owned by the site or others; and
• loading equipment, e.g., loading arms and hoses, where PSM-covered materials are being transferred.

While the PSM regulations do not explicitly call for these equipment types to be included, many are listed above because of written and verbal interpretations of MI by OSHA or by good industry practice. Therefore, a site probably cannot be cited under the PSM Standard for not including them (although OSHA can, and sometimes does, invoke the General Duty Clause for factors that are not explicitly stated in the regulations). However, adding them (either formally or informally) certainly will improve the MI program and process safety.

How to deal with utility systems is an important issue. Whether included formally or informally in the MI program, the ongoing maintenance of some of these systems is critical to process safety. One line of thought is to exclude a utility system if appropriate safeguards are provided. For example, if the loss of cooling water can cause a runaway reaction and if emergency shutdown systems (e.g., temperature and pressure interlocks and trips) are in place, then inclusion of the cooling water system in the MI program is not warranted. This philosophy says that it is acceptable to challenge the SIFs and that the systems that the SIFs protect are not as important as the SIFs themselves. This philosophy should be applied with care.

THE IMPLICATIONS
Beyond determining what equipment should be included in the MI program, what does it mean that MI applies to these types of equipment? What it doesn’t mean is that ITPM tasks are mandatory. Nor does it mean that ITPM is the only activity that must be planned and executed. Being included means that the equipment is subject to the five other sub-elements of MI:

1. Written procedures. The PSM Standard states in 29 CFR 1910.119(j)(2) that “The employer shall establish and implement written procedures to maintain the on‑going integrity of process equipment.” This means that the preventive and corrective maintenance tasks performed on covered equipment must be written down. What isn’t defined is:

What format should be used for these procedures? They can be separate documents, embedded in work orders, attached to work orders or part of a separate manual.

Can original equipment manufacturer (OEM) manuals suffice? In general, this seems to be acceptable — so long as you use the OEM’s most up-to-date and complete procedures for that type and model of equipment. Such use elevates the OEM manuals to the same controlled-document status as internally generated site procedures.

How detailed should the procedures be? How much can you assume about a maintenance technician’s general knowledge from that person’s training? In general, simple tasks such as lubrication do not require detailed explanation. However, the level of detail must be consistent with the complexity of the tasks to be performed and the level of skill of the maintenance work force.

How often, if at all, should the maintenance procedures be reviewed and updated? Should they be certified periodically like standard operating procedures? Formal certification on an annual basis generally is not warranted. However, some sort of periodic review and update is prudent. The provisions of typical ISO or other document-control systems usually suffice.

Should the maintenance procedures contain safety and health information and precautions? This information should be included or referenced in any work order or procedure. If using maintenance procedures from OEM manuals, site-specific safety and health information should be added to the work order.

Should the maintenance procedures be formally approved? Follow the provisions of the document control system as you would for any controlled procedure on-site.

2. Training. The PSM Standard states in 29 CFR 1910.119(j)(3) that “The employer shall train each employee involved in maintaining the on‑going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that the employee can perform the job tasks in a safe manner.”

The process-and-hazard overview training is relatively straightforward — it does not mean PSM or MI overview training but the same type of initial overview training given to the process operators before they begin to actually practice operations in the field. This training need not be highly detailed nor does it have to recur.

The requirement that training be provided in “the procedures applicable to the employee’s job tasks” causes the most confusion. This broad regulatory statement infers the following:
• training in the safe work practices that maintenance technicians will require to perform their work; and
• training (and, in some cases, certified qualifications) in the general craft and specialty skills necessary to perform their work — however, this does not mean that a company or site has to establish a formal apprentice program. Specialty skills requiring certification include: welding; API pressure vessel, tank and piping inspection; non-destructive testing; vibration monitoring; and thermography.

Craft skills can be obtained from an internal training program, from outside sources (e.g., military or union training programs) or provided by properly qualified contractors. Several states have instituted apprentice programs that lead to certification as a maintenance technician. The personnel trained in these programs generally are hired as employees and then enrolled in the training program. Welding on process equipment itself, including pipe fabrication, and on structural equipment that supports the weight or movement of PSM-covered process equipment requires certified welders (certification every six months using outside services or by inspecting and documenting production welds). Other welding on-site, such as work on railings and ladders, might not require such certifications. Other specialty skills generally require outside training and certification.

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