Updated August 12, 2020

According to OSHA standard 1910.119, Mechanical Integrity (MI) is one of the 14 elements included in Process Safety Management (PSM). Maintaining the mechanical integrity of process equipment is important to ensure that assets are not only designed and installed correctly, but also that they operate seamlessly to prevent plant failures, incidents or hazards.

In today’s climate, PSM has become more of a focus as incidents continue to occur in industrial facilities. However, the widespread need for and focus on OSHA PSM Mechanical Integrity continues to present challenges to facilities. To focus on how you can address your current challenges and mitigate risk of loss of containment at your facility, start by tackling the following steps:

Identifying Primary Problem Areas

Common challenges that occur not only at large facilities, but also smaller facilities that may not have the corporate or engineering support, include:

Process Safety Information (PSI)
Issues include incomplete documentation, organization and accessibility, and document control.

Issues include facilities failing to perform process safety management audits entirely, auditing tools being out of date, and plants becoming complacent.

Deficiency Reconciliation
Issues include corrective action follow up/completion and backlog management (specifically around 579 FFS analysis).

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Developing a Written Program

Your MI written program should be an encompassing set of documents that clearly defines how the overall program will specifically operate and integrate into the plant’s PSM program, including:

    • Your plant’s vision for compliance and performance excellence
    • The program structure with specific roles, accountabilities and workflows
    • Performance goals, metrics (KPIs), records and reporting
    • Procedure and document conventions, approvals and maintenance
    • Training and competency assurance
    • Quality assurance (contractor performance, fabrication of new equipment), audits and continuous improvement
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Connecting Your Written Program to Your Actual MI Program

To ensure there is no confusion between your written program and your actual program, the two need to be integrated. To do this, you should:

    • Ensure that your procedure of defining covered equipment is rolled out effectively across your assets
    • Make sure you’re gathering the right data based on the definition of covered assets
    • Make sure you’re doing the right analysis on that data to build good inspection and testing plans
    • Ensure proper work execution of those plans and that data coming back is plugged back into your work process
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After taking all of the information above into account, think about what you are currently doing at your facility to keep on top of your current PSM-related challenges. If you are walking away with a handful of follow up actions, take the initiative to make them happen. Everyone in this industry is working together to solve their own unique PSM challenges to properly mitigate risk around loss of containment at their facilities. PSM challenges can compromise the culture of accountability and excellence which will result in events that impact not only facilities but the industry as a whole, families, and communities.

Question Corner

How often should I be doing audits?

OSHA recommends that to be certain that PSM is effective, employers must certify that they have evaluated compliance with the provisions of PSM at least every three years. This will ensure that the practices and procedures developed under the standard are adequate and that they are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected. The two most recent compliance audit reports must be kept on file.

How do I go about identifying equipment?

By OSHA’s definition, a covered process is a process which might contribute to or cause a catastrophic release of hazardous chemicals, and critical facilities are those that serve to prevent or mitigate catastrophic release.  On that basis, equipment within a covered process (including most utilities), connected to a covered process, or adjacent to a covered process is considered a single covered process.

What kind of KPIs are valuable?

The KPIs that are valuable are the ones that give you the information you need to either do your job or determine performance. It is recommended that all KPI programs be built under a cascading type structure that provides the information needed at each level of the organization. For instance, the KPIs that a plant manager would need should be different than what a front-line supervisor would need. Examples include:

  • Compliance: Out of compliance inspections, forecast based on work scope, etc.
  • Risks: Lagging (leaks; near misses by asset type, unit, and damage type), leading (risk profile across assets), work requests (outstanding inspection work requests by category), MOC evergreening (ensure that the last 10 MOC items are properly processed through your MI program), IOW management (notifications per week/month and appropriate actions)
  • Data Quality: Percentage TML growth, design data checking, metallurgy, etc.

Watch the Webinar

Soak in all of the information listed above in greater detail by watching the full webinar recording here. In addition, connect directly with or submit any questions you may have to the presenters Sean Rosier, Principal of Asset Management Solutions, and Nathanael Ince, Vice President of Client Solutions, by clicking the links below.

Have any questions for the presenters?