The oil and gas industry is facing some unprecedented economic challenges right now but for the past three years, the economy has been very strong overall. Because of sustained economic performance, the industry is seeing more and more facilities evaluating their Mechanical Integrity programs, not only in the function of the MI program itself, but also how it incorporates into their PSM program. 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

The first area where facilities often struggle is centered around Process Safety Information (PSI). PSI is the information that is designed to enable everyone from the employer to the employee, contractor, or anyone who is involved with operating the process, to be able to identify and understand the hazards posed by processes involving highly hazardous chemicals. Issues include:

Incomplete Documentation

Most facilities have a handful of documents pertaining to the equipment in the process (U1s, equipment drawings, etc.) but many struggle with having incomplete documentation. When you consider that PSI needs to include data pertaining to the hazards of chemicals used or produced, along with information pertaining to the technology of the process, gaps start to become more prevalent. To ensure you have complete documentation:

    • Be sure you have all your equipment data: In addition to U1s, consider things like post weld heat treating documents, PMI documents, and IOWs. They all should be included.
    • Include the engineering design documents: Things like process models, process narratives, cause and effect matrices, and interlock documents should all be part of PSI.
    • Start by checking with your capital projects group: They should have a standard corporate list of what they require their engineering contractors to provide them when they deliver the engineering package. Use this list to go through and see what you have and what you do not have.

Organization and Accessibility

Many facilities have information that is unorganized and difficult to find, stored in different areas and platforms. Information is kept in a variety of forms and places, such as digital format, in a file cabinet, or kept on specific departmental drives with limited access. Create an organizational system for your information that can be easily accessed across departments to ensure everyone is on the same page at your facility.

Document Control

Ensure that the information you are looking at is the correct information. You might think that your MOC process takes care of this, but consider this scenario: if you have a plant that was built and has been in operation for several years prior to the implementation of the 1910.119 standard, there is a distinct possibility that you might need to review your documentation to reflect what you are currently working with.

Auditing

The second area where facilities often struggle is auditing. Issues include:

    • Audits not being performed: Auditing isn’t held as a priority by the facility.
    • Auditing tools that are out of date: A facility may have gone through some MOCs, updated standards, or acquisitions, but the auditing tools have not been kept current.
    • Plants can often become complacent: Some facilities can feel that they have a well-functioning program – they are performing inspections, gathering data, analyzing the data, and doing everything you would naturally think an MI program should do, but the issues arise from other PSM requirements, not just the functional ability of the MI program.

Helpful Tip

In the last year alone, several facilities that had functioning MI programs performed all of the items mentioned above. After diving deeper into their program, it was discovered that they had not developed a list of their PSM covered equipment and associated boundaries. This a basic requirement of the PSM standard that must be in place to clearly identify what chemicals are onsite, what threshold levels are attained, and in turn, what equipment is covered under the PSM program. The plants were able to get these analyses/lists in place but without auditing practices, things like this can get missed.

Deficiency Reconciliation

The third area facilities often struggle is deficiency reconciliation. Issues include:

    • Corrective action follow up/completion: Ensuring that all the corrective actions that come out of an investigative study (RCA event, a 579 FFS analysis) are completed is key. It is crucial that you have a stringent process in place that assigns accountability and ensures that tasks have been completed and documented.
    • Backlog Management, specifically around 579 FFS analysis: Facilities may struggle with resourcing for this work and, as such, staying on top of known issues can be a challenge. Reach out to people who have this type of expertise to stay on top of backlog management.

Helpful Tip

An excellent example of this is follow ups from auditing. There have been instances where a facility's PSM group will perform an audit and then pass on the findings to various respective groups without any real hand-off or base information to help correct the finding. Defining the issue, assigning accountability and being sure the task was completed is a must.

What's Next?

After you have identified primary problem areas, develop a written program in order to understand how your MI program works inside of your PSM program. Learn how by checking out Tackling Core Challenges Around PSM MI: Developing a Written Program.

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