After identifying primary problem areas at your facility, begin tackling your challenges by developing a written program in order to know how your MI program works inside of your PSM program. Everyone at your facility should know the procedures of your PSM program and these procedures should be evaluated regularly.

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. It should include a fully integrated set of practices, procedures, and workflow instructions on not only how the MI group should conduct their day-to-day operations, but also how the group will integrate and interact with other supporting functional groups. The procedures should contain information specifically attributable to the equipment needs at the site. Specific damage mechanisms, geographic location, seasonal weather conditions, specific process conditions, and the like should also all be addressed in these procedures.

Helpful Tip

Take your written MI program and hand it to someone that might not be as familiar with mechanical integrity as you are. If they can go through it and easily understand how the program functions and how everything works, then you know that you have a solid written program.

Traditionally, written programs tend to focus primarily around equipment-specific procedures, such as how to inspect a piping circuit or pressure vessel, but when you are talking about integrating your MI program into your PSM program, there is much more to consider. First, it is important to note that although Mechanical Integrity is one of the 14 elements of PSM, it is also the one that utilizes every other element the most. Everything from process safety information to employee involvement to auditing to deficiency reconciliation all feed into your Mechanical integrity program. Your MI written program must take that into account. When you are looking at your program, it should include, in addition to your equipment-specific documents and guidelines, things like:

    • 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

To get started with this, the first step in developing your written program is to put together an outline, or table of contents, with narratives of what will go into each document. You should also put together a data flow through your outline to see if it makes sense and that it is hitting the requirements.

Second, gather all your existing procedures and see what you have already.  Many times, facilities have good chunks of procedures that just need to be better organized into a more cohesive program rather than just a procedure. Once you have these in place, put together a roadmap of how you are going to write the procedures. Be sure to think about the document controls aspect, who is going to write versus who is going to quality check and who can approve the documents. In addition, you need to appoint a champion within your organization that will ensure the success of your program.

One more thing to keep in mind here is that a specific portion of your written program should pertain to training. Training is one of the 14 elements of PSM, but many times it is the most overlooked in written program. Things to keep in mind include:

    • Contractor management – Be sure you have clear definition around what skills and certifications you require your contractors to have, know how you are going to keep your records updated, and identify how you are going to ensure that you are getting what you are paying for.
    • Think about how you are going to go through with training your people. Many facilities have some sort of centralized training record that has everything you need not only for your MI program, but also for your PSM program.
    • Understand that it is about making sure people are trained on your program and everything in your plant. Your safety department needs to be involved, especially if you are having people come in and out of your plant.

What's Next?

After you have identified primary problem areas and have developed a written program, connect your new written program to your actual MI program to make it a reality in your day-to-day operations. Learn how by checking out Tackling Core Challenges Around PSM MI: Connecting Your Written Program to Your Actual MI Program.

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