Repair Your Mechanical Integrity Program

The first step in creating an effective mechanical integrity program is to accurately interpret how these broadly written performance-based requirements apply at each site.

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

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3. Inspection and testing. The PSM Standard states in 29 CFR 1910.119(j)(4): “Inspections and tests shall be performed on process equipment. Inspection and testing procedures shall follow recognized and generally accepted good engineering practices (RAGAGEPs). The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and shall occur more frequently if determined to be necessary by prior operating experience. The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.”

What are  governing RAGAGEPs? The three most common forms are:
1. federal, state or local law or
2. ITPM recommendations made by an OEM; and
3. consensus codes, standards and other guidance published by industry and professional organizations, such as the American Society of Mechanical Engineers (ASME), American Petroleum Institute (API), National Fire Protection Association (NFPA), International Institute of Ammonia Refrigeration (IIAR), etc.

While these are the most common and recognized forms, RAGAGEPs can come from other sources.
Written company policies and procedures may constitute RAGAGEPs. In general, they do because OSHA usually treats such procedures as compliance requirements.

Guidance published by insurance companies may represent a RAGAGEP. Sometimes insurance companies issue consensus guidance or by common and frequent usage such works become consensus guidance. For example, many Factory Mutual standards have become consensus fire protection guidance — and so apply.

Plant-specific equipment history may represent a RAGAGEP. For some type of equipment no other sources of information or guidance for planning ITPM tasks and their frequencies exist other than the operating history of the equipment itself. Hence, it becomes a RAGAGEP of sorts or at least a source of data upon which ITPM decisions are based.

There is frequent confusion regarding the selection of the frequency of ITPM tasks, particularly when the RAGAGEPs do not specify a frequency. This is a common situation for rotating, instrument/electrical and other equipment types.

Can the frequency of the ITPM tasks be less than the manufacturer’s recommendations? Although the PSM Standard does not explicitly address this point, common practice indicates that a lower frequency is allowable as long as documented evidence of previous ITPM results justifies the extension and a management of change (MOC) or equivalent program on-site is used to review and approve such changes.

Is overdue ITPM a compliance issue? Yes, because if the RAGAGEP specifies a time period that has been exceeded, then the RAGAGEP is not being followed. Also, a published ITPM schedule represents a company/site procedure and not performing maintenance on time means you are not adhering to an approved procedure.

4. Deficiencies. The PSM Standard states in 29 CFR 1910.119(j)(5) that the employer shall correct deficiencies in equipment that are outside acceptable limits before further use or in a safe and timely manner when necessary means are taken to assure safe operation.
MI deficiencies (i.e., equipment operating outside acceptable limits) can stem from a number of sources:

• out-of-specification ITPM results; For example, the API-510 and API-570 pressure-vessel and piping inspection codes specify formulas to be used to calculate the minimum wall thickness of vessels and piping. If ITPM results indicate that these thicknesses have been reached, then such results are deficiencies.
• equipment operating beyond safe upper or lower limits as specified in either the RAGAGEPs, operating procedures or design documentation; For example, a MI-covered pump that is operating below the head-versus-flow specifications on its pump curve would be a MI deficiency if the pump provides a critical service.
• loss of containment of any PSM-covered material, e.g., a leak from a pump seal; and
• bypassed or removed safety features.

Are overdue ITPM tasks considered deficiencies? Although the frequencies of these tasks are determined from RAGAGEPs and, hence, should not be exceeded, overdue ITPM tasks are not treated by regulators as MI deficiencies; companies, however, should treat them as such to emphasize their importance.

Equipment with a MI deficiency can be operated for some temporary period of time. This time period should be reasonable given the nature of the deficiency and the time needed to plan and execute the permanent repair. Temporary safety measures (e.g., decreased throughput, reduced pressures or temperatures, lower relief-valve setpoints and more frequent ITPM) must be implemented if warranted. Sometimes, an evaluation of the deficiency will show that such temporary safety measures are not needed — i.e., the equipment as-is can be operated safely until it can be shutdown for permanent repair. If temporary safety measures are necessary, you must follow the site MOC procedure to implement them. The evaluation of the deficiency, its seriousness and the need for temporary safety measures must be performed on a case-by-case basis for each deficiency and this process should be thoroughly documented in each case.

5. Quality assurance. The PSM Standard states in 29 CFR 1910.119(j)(6): “In the construction of new plants and equipment, the employer shall assure that equipment as fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer’s instructions. The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.”

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