Quality assurance (QA) in this context does not refer to product quality or ISO-related quality concepts. Instead, QA refers to the process of ensuring that the PSM-covered equipment is designed, purchased, fabricated, installed and commissioned properly and that these processes are controlled and documented. Most of this activity involves the organization and execution of engineered projects. Although the PSM Standard does not explicitly require procedures for these activities, to successfully control engineered projects, regardless of their size, scope or cost, demands that procedures be implemented to govern their technical and administrative aspects. For example, the site should have a pipe specification to cover the design of piping in PSM-covered processes or approve the use of a contractor’s specification. A project manual/procedure that specifies how engineered projects are administered, including documentation, is generally a necessary prerequisite to ensure technically correct and consistently managed projects.
There also should be proper controls over the ordering, receipt, storage and disbursement of spare parts and material for PSM-covered processes to ensure that the right part is used in the right application. In the context of MI, spare parts management has nothing to do with the economic management of the storeroom or warehouse.
A MULTI-GROUP EFFORT
Given the above interpretation of what a MI program should contain, the responsibilities for planning and executing the necessary activities are broadly distributed throughout the site and cover the lifecycle of equipment:
• ITPM (determination of ITPM tasks and their frequencies, planning, scheduling, execution and documentation) — usually the responsibility of the maintenance group. However, at many medium-to-large facilities, these activities are split among an inspection group, rotating machinery group and instrument/electrical group.
• Repairs/corrective maintenance — typically managed by the same groups as ITPM work, with contractors frequently involved as well.
• Training and qualification of maintenance technicians (design of training qualification, determination of final qualification criteria, conduct of training and documentation of training and qualification process) — usually a split responsibility between a safety/training group (safe work practice and other environmental/health/safety-related training) and the group handling the ITPM/repair work.
• Written procedures (creation of procedures, filing/maintenance of OEM manuals) — generally provided by the group where the work is performed. If the site is ISO certified, a document control group also is involved because the documents in question generally are controlled ones.
• Engineered projects (organization, execution and documentation of projects) — usually the responsibility of the engineering group, although the maintenance group sometimes performs the installation activities for smaller/simpler projects. Contractors frequently are heavily involved in these activities.
• Spare parts management (ordering, receipt, storage, disbursement and documentation of spare parts) — the storeroom or warehouse is the responsibility of either maintenance or purchasing.
• MI deficiency management (reporting and evaluating deficiencies and executing temporary and permanent corrective measures) — typically the responsibility of maintenance. However, the entire process of managing deficiencies involves other personnel on-site (e.g., those who manage the MOC program).
The total scope of responsibilities for performing MI activities spans nearly every major group and discipline on-site. Some of the persons in these groups may not be aware that their job responsibilities involve fulfilling MI requirements. This mostly is an awareness problem. For the MI program to work properly, it is imperative that all of its activities be defined and then the responsibilities for these activities be carefully assigned and communicated.
TYPICAL PROGRAM WEAKNESSES
Now, let’s look at common findings from examining MI programs during PSM audits and related work. Some cover aspects that, while not explicitly required by the PSM Standard, would help alleviate compliance-related issues and institutionalize good policies, practices and procedures.
Applicability. Many times a consolidated list of equipment included in the MI program does not exist or exists in multiple types of records maintained by different people. Although creating a single list or register of MI-covered equipment as a controlled document is not an explicit requirement of the PSM Standard, this would help alleviate the awareness problem of diverse groups across the site not knowing that the equipment they are responsible for maintaining is part of the MI program and hence subject to all elements of the MI program not just ITPM activities.
Many of the non-mandatory equipment types described above (e.g., fire protection) clearly are important to process safety and require the same activities as the equipment that must be included in the MI program. Yet, many programs ignore these other equipment types, leading to many ITPM tasks not being planned and performed and also many deficiencies not being managed properly.
Written procedures. The collection of OEM manuals, home-grown procedures and embedded work-order task instructions that constitute the written maintenance procedures often is not complete.
OEM manuals frequently receive little maintenance. Many are not catalogued or indexed so that an inventory of them can be maintained. Although there is no need to convert these vendor manuals into official controlled documents, some management of them is necessary to ensure that the plant has all that are relevant and they are maintained properly.
Another common issue is the lack of approved procedures for welding on process equipment performed by employees or contractors.