PEI Codes and Standards, Work Processes, Data Management, and Continuous Improvement to achieve Excellence in a PEI program

By John Reynolds, Principal Consultant at Intertek. October 28, 2013
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Today’s blog post is a continuation on the 10 essential Management Systems needed for an effective PEI program that can achieve excellence. My previous posts covered the first six of these, including LCM, Risk Assessment and Inspection, and Deterioration Management and Control, among others. This post covers the last three:

7. PEI Codes, Standards and Regulations

As the name implies, this PEI MS drawer contains all the necessary information on industry codes, standards, recommended practices and regulations that apply to PEI. As you can imagine, this is more of a library than a single drawer in our PEI MS filing cabinets, as it contains a large compilation of documents written by standards development organizations (SDO’s) like API, ASME, ASNT, ASTM, NACE, NB, etc. and various local, state and federal regulations that apply to pressure equipment in our industry. A new publication by the ASME provides excellent guidance on all the codes and standards in North America that apply to LCM of pressure equipment. These industry codes and standards cover the entire range of LCM from design through fabrication, construction, inspection, fitness-for- service evaluation, repair, replacement to retirement. For the most part they are outstanding documents that comprise best practice requirements and recommended practices from some of the industry’s top experts in their field of expertise working under the consensus building rules of the American National Standards Institute (ANSI). Companies that don’t make full use of the latest editions of these industry standards are missing the boat.

8. Site Procedures and Work Processes for PEI

To supplement the industry codes and standards, companies and their individual operating sites typically have their own company and/or site-specific standards, procedures and work processes; the purpose of these being to fill in gaps in the industry standards and to make the industry standards site-specific. Industry codes and standards provide a lot of valuable information, requirements and recommended practices to accomplish excellence in PEI; but because they need to be generic to apply to a wide range of organizations and practices in industry, some amount of site/company- specific procedures and work practices are very necessary in order to accomplish all the necessary tasks at your site. Some examples of company/site specific procedures and work practices include NDE procedures and contracting, maintenance contracting (for PEI issues), PEI planning for turnarounds, access to PEI engineering assistance when needed, PEI repair planning, etc.

One of the most important of site specific work practices is to indicate who is accountable and responsible to accomplish all the details in the PEI MS in the other drawers of our filing cabinets, and what is the role of not just the PEI group in maintaining pressure equipment integrity, but also the role of operations, maintenance, engineering and anyone else involved. Timing of each activity is another critical facet of the work process description of aspects each activity in each PEI MS. As I’ve mentioned in the high level description of each of the previous PEI MSs, this one is also totally integrated with the other 9 PEI MSs.

9. PEI Record Keeping and Data Management

This is perhaps one of the most mundane of the necessary PEI MS, but unfortunately also one that can be very ineffective and inefficient if not done well, thus taking a toll on the whole PEI process. In my 40 years of experience in this business, I long ago came to realize that if a site does not do this PEI MS well, then they are not likely to do well at any of the other 9 PEI MS, and subsequently are not likely to have a good record of PEI excellence (as defined earlier). Hence, I place a very high value on doing an excellent job of PEI record keeping and data management, not only for efficiency and effectiveness reasons, but for legal reasons. As we all know, regulators and courts of law take a very dim view of poor PEI record keeping. Clearly, computerized record keeping is nearly a requirement when it comes to keeping track of all the PEI data and information necessary to achieve excellence in PEI. As nearly everyone knows by now, Inspection Data Management Systems (IDMS) don’t function well with questionable and inaccurate data, and subsequently can take a huge toll on inspection productivity, let alone the possibility that the garbage-in garbage-out (GIGO) syndrome can also result in breaches of containment. And while this issue mostly affects the progressive inspection history files, we don’t want to overlook the need for good quality design and construction files as well as repair, alteration and rerating files.

10. Continuous Improvement for PEI

Last but not least as the saying goes, a high quality continuous improvement PEI MS is the hallmark of the best PEI programs that I know about. After all the foundational building blocks for a PEI program are in place and functioning effectively and efficiently, we come to all the methods and tools that allow us to make improvements in our program, especially if we have breaches of containment. In a succeeding article on this PEI MS, I will describe the various initiatives that can contribute to continuous improvement in PEI, including: incident and near-miss investigation and solution development, leak and failure analysis and reporting, PEI root cause analysis, learning from incidents, PEI networking (inter/intra company), company failure memory systems, PEI performance measurement metrics, PEI audits/reviews and causal learning. Without using and learning from some or all of these methods and tools, we can’t really improve our PEI programs and achieve PEI excellence.

So there you have it – a high level overview of the 10 PEI MSs that are necessary to achieve and maintain excellence in PEI, which is the bull’s eye of our PEI target. If all you want is “compliance”, whatever that is, then some may think they don’t need all this stuff. But in my 40+ years of experience in this business, I take a dim view of those just seeking the minimalist approach for “compliance” with regulations. First of all with that approach, they rarely ever achieve or stay in compliance whether they want to admit it or not. And secondly, “compliance” is not the be-all end-all of a successful business plan. Whereas, pressure equipment integrity, and the subsequent pressure equipment reliability, are part of a good business plan. It takes PEI excellence to achieve the latter.

I find that these PEI MS are always improving and expanding to keep up with changing business conditions and requirements. If there are any PEI MS that you have at your site that I may have overlooked, go to the Inspectioneering LinkedIn Group to share it with us.

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