(143a) Nothing Lasts Forever: Items Missing from Your Preventative Maintenance System

The United States (US) Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard 29 CFR 1910.119 is a performance-based management system regulation intended to prevent catastrophic releases of hazardous chemicals. Due to the number of serious Process Safety incidents that have occurred from the implementation of the PSM Standard, OSHA has implemented National Emphasis Programs to audit process safety compliance at refineries and chemical processing plants. Both the Refinery and the Chemical National Emphasis programs identified Mechanical Integrity as the element with the largest number of compliance gaps.

One of the challenges facing companies in the implementation of an Asset Integrity System is drawing the system boundaries. Often, smaller critical items, such as check valves and other piping specialties, are not included. The large number of these items that often exist in a processing unit can make identification of the critical items difficult. However, failure to test/inspect such items have resulted in major incidents.

This paper aims at providing guidance for identification of critical items, their required inspection frequencies, documentation required, and deficiency resolutions for inclusion in an Asset Integrity system. This guidance is based upon experience, Recognized and Generally Accepted Good Engineering Practices, learning from incidents and best practices.

An overview of the techniques used to identify the scope of an Asset Integrity System will be provided. Learning from incidents, including outside the Chemical Processing Industry, that have occurred will be reviewed to illustrate the importance of smaller, often overlooked, items that became root causes. The goal of this paper is to provide the reader with guidance on identification, inspection frequency, documentation and deficiency resolution of critical equipment that not only satisfies the regulatory requirements but also includes all items, including small often overlooked items.

An effective Asset Integrity system is an important part of a compliant and effective Process Safety Management System.