Inspection Reporting by Inclusion, Not by Exception

Have you ever wondered why, even though inspection reports are one of the primary keys to a good mechanical integrity (MI) program, they are so rarely reviewed? One of the things I always find when reviewing a program is the lack of concise inspection history. Since I became involved with inspection prior to the inception of OSHA’s process safety management (PSM) regulation, I remember the inspection reporting philosophy of “managing by exception.” Simply put, if nothing was found to be unacceptable, then nothing–and I mean nothing–was reported. It wasn’t uncommon to find checklists that were left completely blank with the only wording on the report being something to the effect of “no nonconformances noted.” 

In 1992, when OSHA PSM became law in the United States and mandated mechanical integrity, many owner/users who were doing inspections generated reports like the example above. While many companies scrambled to get all 14 parts of the regulation in place, it would appear that reviewing inspection history was oftentimes neglected. Those original inspections were mainly comprised of three techniques:

• Visual internal
• Visual external
• Ultrasonic straight beam

This complied with how API 510, 570, and 653 were written at that time. These standards eventually evolved to include requirements that tie inspection techniques to anticipated damage mechanisms. However, inspection reporting did not evolve as quickly and many owner/users continued on with the practice of “reporting by exception.” Even now, in the year 2021, this type of reporting still occurs.

With all of the regulatory incidents along with the accompanying audits and recommendations by federal, state, and local agencies, we continue to advocate “report by inclusion” (rbi). This means that every inspection report, regardless of technique, should have the following minimum information as part of it:

• The inspector’s name, company, date of examination/inspection as well as his/her current credentials.
• Proper documentation of the inspection technique used which should include all parameters in order to recreate it. This should include all calibration parameters for any NDE.
• The original design conditions of the equipment including any safe operating limits from the current operating procedures.
• The acceptance criteria for the inspection.
• The inspection extent which should include a good description of all examined areas. As an example, this could be a percentage of total surface area or of the total number of locations. This should also include any areas that were not available for inspection and why they were not examined.
• The damage mechanism and a thorough description of its corresponding damage extent. For damage mechanisms with trendable data, this would include the damage/corrosion rate.
• A repair plan, if required, detailing what needs to be repaired, when it has to be completed, and the new acceptance criteria to declare the repair fit for continued service.

This agrees with API RP 572, 4th edition, Section 11.2.

This “report by inclusion” approach yields the following:

• A better understanding of what was examined. This allows for the classification of inspection effectiveness, as defined in API RP 581 3rd edition, Section 3.1.37.
• A better understanding of what was found.
• A better record for the reviewer/analyst to process and provide any possible recommendations.
• A more accurate inspection history which allows the owner/user to make better decisions with regard to:
• Whether or not a damage mechanism is present
• Shutdown inspection planning
• Individual inspection deferral
• Repairs or replacements 

Whether you are working with a time/condition-based or risk-based inspection program, the days of “reporting by exception” should be behind us. Every MI/RBI program needs a little rbi.

Let’s continue the conversation! I am interested in your feedback. Please leave a comment below to start the conversation.