Common Audit Findings 3 – Mechanical Integrity Issues

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Introduction Process safety audits frequently uncover confusion regarding PSM program requirements and implementation. This is Part 3 in a five-part series highlighting common audit findings. This section includes selected audit findings related to Mechanical Integrity.

Selected Audit Findings (see reference for complete list)

Mechanical Integrity

General MI Program: Some facilities may have implemented preventive maintenance practices but have not developed fully documented MI programs as required by the regulations. In other cases, all the equipment associated with the covered process may not have been identified and included in the MI program. Gaps in the program may be identified by review of the regulatory requirements, auditor review of facility PSI (e.g., equipment files, safe limits tables, safety system and emergency response equipment), and/or auditor knowledge of RAGAGEPs. In addition, auditor review of PHAs may help identify safeguards that have been credited for helping to prevent or mitigate the consequences of potentially hazardous scenarios, but which have not been included in the MI program.

Guidance: Ensure equipment associated with covered processes has been broadly reviewed for possible inclusion in the MI program, based on regulatory requirements, PSI documentation, PHA review, and RAGAGEP requirements. Consider identifying “PSM critical” equipment as part of the PSI equipment documentation, based on the potential consequences of equipment failure or malfunction. Document equipment types and the requirements for each in the ITPM plan (see below).

 

Maintenance Procedures: In many cases, maintenance procedures have not been developed and documented for equipment associated with the covered processes to ensure that ITPM activities are conducted appropriately and consistently by qualified personnel with proper documentation of the results. In some cases, procedures may be available from the manufacturer but have not been implemented in the procedures that have been developed. Maintenance procedures may also not be provided for common maintenance activities, such as equipment lubrication or calibration or to address RAGAGEPS requirements. Procedural gaps and lack of direction or training for maintenance personnel can result in ineffective inspection, testing, or other maintenance activities, leading to higher risk of equipment failure and hazardous incidents. Missing test activities can lead to poor evaluation and follow up on equipment needing attention.  Missing or poorly documented historical test data can also prevent proper evaluation of reoccurring operating issues and remaining equipment life.

Guidance: Develop maintenance procedures for all required process equipment and work tasks based on manufacturer guidance and any related RAGAGEP requirements. Ensure procedures are specified for specific inspection and testing tasks and include requiring proper documentation.

 

Maintenance Training: Failure to provide training on an overview of the process and its hazards is a common finding. OSHA requirements are for maintenance personnel to be trained on the hazards related to equipment they are working on as well as the applicable MI procedures. This issue is more often observed with maintenance shops considered “central maintenance” facilities where all mechanics/technicians are part of one group and are dispersed throughout a large plant to different PSM-covered areas rather than being dedicated to a limited number of processes. Some of the reasons for this include (1) not receiving all required training when newly hired, (2) the plant added a new process area and failed to provide overview training to all maintenance personnel, or (3) personnel were operators in a particular part of the plant and changed position to maintenance technicians and were not subsequently trained on other areas in the facility.

Training must also be provided on the maintenance procedures, safe work practices, and use of special tools or equipment, as needed. In some cases, specific tests or inspections require the use of certified inspectors per the RAGAGEP, and appropriate certifications must be obtained or qualified external inspectors brought in to conduct the activity. In addition, maintenance personnel should be trained on emergency response plans and management of change (MOC) procedures.  Although not required specifically by the MI element, proper documentation of the training provided should be maintained.  Refresher and/or special skill training should also be provided as needed.

Guidance: Develop a maintenance training program to ensure training is provided in all required areas.  Documentation, including verification of understanding, should be considered. Increasingly, trade or trade school training is being considered a prerequisite for being hired into maintenance roles. Based on required work activities, the development and training of internal certified inspectors should also be considered and addressed.

 

ITPM Plans: Findings related to development and implementation of ITPM plans often include:

  • No ITPM plan
  • Incomplete or incorrect ITPM plan (missing equipment types or relevant RAGAGEPs)
  • Inspection not done or not done on the required frequency
  • Inspection not done using approved maintenance procedure
  • Inspection not done by trained maintenance personnel or qualified/certified inspectors
  • Poor documentation of inspection results
  • No review and/or follow up of inspection results, including corrective actions or program adjustments

Guidance: Document an ITPM plan, using approved tests and inspections, to maintain required equipment. In addition, have a process for identifying when RAGAGEP requirements have been changed and for evaluating the needed updates, if any, to the ITPM plan and MI program.

 

Equipment Deficiencies: Many sites have not developed a formal program to (1) review equipment deficiencies and (2) ensure proper steps are taken to respond to issues such as leaks, failed inspections, reaching minimum allowed thickness (Tmin), operating beyond operating or safe limits, failed welds, etc. These situations must be managed to ensure the integrity of the equipment and safety of personnel.  The equipment deficiency program should consider if equipment must be (1) shut down until fixed, (2) run at lower operating rates (temporarily or permanently), (3) possibly bypassed until repair or a replacement part is obtained (typically temporarily), or (4) replaced. The program should also ensure that the proper risk assessments are made, documentation is provided, and appropriate authorization is received. Fitness-for-service evaluations, based on historical operating and inspection data, may need to be conducted, especially if frequent problems have occurred.

Guidance: Document an equipment deficiency program for responding to equipment operating or inspection deficiencies, which should include proper documentation of the path forward (e.g., bypass authorization procedures, temporary MOC for modified, equipment shutdown/repairs), review, and authorization to proceed.

 

Quality Assurance: Many sites have no quality assurance (QA) program in place as required by the MI element.  Some may have corporate directives that direct the site to establish a QA program or provide additional guidance on specific practices, but this is often observed to be only partly implemented or not specific to site needs and practices.  Documentation that appropriate checks and inspections are being conducted during equipment fabrication and installation is often not available or incomplete. Material verification programs are not provided, may not be documented, or are inconsistent or ineffective. A wide range of approaches has been observed related to the availability and organization of equipment spare parts from typical warehousing controls to specialized spare parts programs. Lack of correct spare parts can lead to imperfect maintenance and operating decisions when equipment failures occur.

Guidance: Document a QA program for equipment fabrication or receipt that includes inspection, verification, and installation procedures and maintains appropriate spare parts inventories and controls.

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References

 

The published version of this complete article can be found on Chemical Processing’s website where you can also access more tools and resources to help you run safe, efficient facilities.

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