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.
Auditing
Issues include facilities failing to perform process safety management audits entirely, auditing tools being out of date, and plants becoming complacent.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).
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
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
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.
Watch the full webinar here.