Energy organizations such as chemical manufacturers, oil and gas production, and even pharmaceutical manufacturers strive to maintain a Process Safety Management (PSM) program to ensure the safety of their employees and those around their facilities. Many of these organizations are familiar with the requirements of PSM including the process of conducting Process Hazard Analysis (PHA) and the documenting and training for operating procedures. But many of these same organizations struggle to ensure regulatory compliance and best practice of their mechanical integrity programs, which are required within the PSM program framework.
The OSHA Process Safety Management (PSM) Program requires a mechanical integrity program for the protection of the primary and secondary levels of defense for unwanted chemical releases. The first line of defense is operating and maintaining a process facility as designed. The second line of defense is the protection systems such as fixed fire water systems, dikes, deluge systems, etc. A mechanical integrity (MI) program strengthens and protects these lines of defenses where appropriate. Therefore, ensuring that a MI program is established and suitable to enable this protection is the regulation’s intent and is also a key aspect for the energy organization.
Mechanical integrity programs come in all shapes and sizes, but they start with the same key elements. The following elements serve as the foundation to a PSM regulated MI program:
- Scope of the mechanical integrity program
- Equipment and process categorization within scope
- Inspection and test plans and criteria for acceptable results
- Documentation of the program, equipment design, and manufacturer recommendations such as meantime to failure for equipment and instrumentation
- Development of maintenance procedures
- Training of personnel
When addressing or establishing the mechanical integrity program, consider addressing some of the following items:
- Scope of the mechanical integrity program – Strong MI programs have a defined scope that meets the goals of the organization. Scope to consider could entail which part of the organization owns the MI program and its importance within the organization. Similarly, consider what areas, units, and process systems will be included within the process scope outside of regulated PSM chemicals. As for goals, is it the goal of a MI program to meet safety regulation or are there additional areas where MI could add value, such as optimization of turnaround scopes and maintenance programs? Value returned and regulation compliance can be considered as goals of equal importance when developing the MI program.
- Equipment and process categorization within scope – As determined by the scope and the organization’s goals, the equipment and processes should be categorized to address areas of focus within the program. Areas of high risk would require more inspection and maintenance scrutiny, where areas of low risk are established as an area to optimize inspection, maintenance, and test plans.
- Inspection and test plans and criteria for acceptable results – Inspection and test plans are derived from industry codes and standards as well as other methodologies. Organizations should consider if risk-based, condition-based, time-based, or other criteria will be utilized to establish and maintain inspection and test plans. When establishing acceptance criteria, competency of the inspections, the organization’s risk tolerance, or the acceptable equipment damage may influence the acceptance criteria.
- Documentation of the program, equipment design, and manufacturer recommendations such as meantime to failure for equipment and instrumentation – Documentation of the program is essential to protect the equipment and MI program from personnel turnover or MI tool changes. When considering how to document the MI program, organizations should consider establishing their current equipment documentation foundation by documenting equipment design parameters. Then work to document the MI program processes and procedures while also documenting the manufacturer recommended meantime to failure frequencies and the methodologies used to establish inspection and test plan procedures.
- Development of maintenance procedures – Included within an effective and compliant MI program will be documented maintenance procedures. Organizations should consider how and what should be included into the maintenance procedures that address mechanical integrity and then document these procedures. As an example, a maintenance procedure worth documenting as part of the MI program could be the relief device maintenance and testing program.
- Training of personnel – As with all programs, personnel within or affected by the MI program should be fully trained and aware of the program. Consider developing training not only for the personnel involved in the daily MI program activities, but also consider developing a management training to ensure that management are aware of the key performance indicators (KPIs) of a MI program and what will be required of them when it comes to MI program needs and expectations to maintain an effective MI program for the organization.
The above elements and accompanying considerations are only the surface of an effective and compliant PSM program. Consider inviting Cognascents to review, establish, develop, and maintain your mechanical integrity program. We can assist you in finding the best fit and most cost-effective MI program customized for your organization.