We’ve talked a lot about the need for regulations in the chemical, petroleum, and manufacturing industries, as well as why you should have a mechanical integrity program and the different types of inspections that program might include. You are probably familiar with OSHA, the US Occupational Safety and Health Administration. In order to ensure safe and healthy workplaces, and to protect the environment from the release of hazardous chemicals, OSHA issues standards for industries to follow. Process Safety Management is the overall approach to following these standards and managing the hazards associated with these industries.
OSHA Standard 29 CFR 1910.119 includes fourteen sections, encompassing topics such as ensuring that all employees are involved in the program, documentation regarding the chemicals being used at the location and how the plant’s process operates, information about what could go wrong and how to stop that from happening, establishing procedures for the operation of your plant, training employees / contractors, emergency planning, and compliance audits. It also includes mechanical integrity – ensuring that the equipment which handles hazardous substances is continually safe to operate.
Equipment included under the mechanical integrity section might include pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls such as sensors, alarms, and interlocks, and pumps. The OSHA standard requires that procedures must be created and implemented to inspect this equipment, and that the people performing the inspections need to be properly trained on what the potential hazards are and how to perform the inspections safely. Because each plant has its own combination of equipment, processes, potential hazards, and already-implemented inspection and safety procedures, the OSHA standards can’t say specifically what needs to be included or how to do it. Instead, it says that inspections and testing are to be “consistent with recognized and generally accepted good engineering practices”.
That statement leaves room for interpretation and confusion. Eventually, OSHA issued clarifications, and said that following the guidelines established by the American Petroleum Institute (API) for inspecting process equipment would satisfy the Process Safety Management mechanical integrity requirements. (Read more about the various mechanical integrity certifications and why you should hire an experienced API inspector in our previous Fun Fact Friday posts!) Companies who already had their own recognized good engineering practice in place when this standard was established, generally leaders in their field, were able to continue using their system.
“Generally accepted good engineering practices” include performing inspections at recommended intervals and maintaining records of those inspections, as well as ensuring that any deficiencies identified during inspection are corrected. It also encompasses new equipment, and ensuring that it is fabricated per design specifications and is suitable for the process application it will be used in, as well as that it is properly installed. When a situation where the design codes, standards, or practices which existing equipment was based on are no longer in general use, the company must assess the best method for its inspection, and may need to adjust their policies and procedures to account for this. The company’s written policy must also be adjusted when changes to the its process chemicals, technology, equipment, or procedures take place.
What happens when deficiencies are found during inspection? Perhaps equipment was found to be outside of acceptable limits, but was not repaired in a timely manner. Maybe inspections were not documented, or were not performed at all. If situations such as these are discovered during an audit by OSHA or a third-party agency, the company may be cited and / or fined. These fines can run into the millions, and can hurt a company’s reputation as well as impact their ability to operate. In order to avoid these situations, and to protect employees and the environment, it is vital to have a Process Safety Management Plan in place.
Encorus can help you ensure that your company’s plan is compliant and current, and assist in inspection services. Call Keith Taylor at 716.592.3980, ext. 143 or email him at [email protected] for more information.