Risk Based Inspection and Regulatory Compliance - They Can Co-Exist

Inspection to determine mechanical integrity is important to verify that equipment is suitable for intended use, i.e. to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals as required by OHSA 1910.119 - Process Safety Management of Highly Hazardous Chemicals (and other jurisdictional codes).

Risk-based inspection (RBI) is a program/ methodology for evaluating risk—how much risk, where is the risk, and when to inspect/re-inspect for controlling risk. With facts from a risk-based inspection program, activities can be prioritized for individual equipment in a plant by identifying the likelihood of failure (the probability of failure) and the consequence of failure ($s if the event occurs). The desired result of a risk-based inspection program is to simultaneous achieve lower risks and lower costs.

A very important part of the whole issue is to assure regulatory compliance standards are satisfied, too. The purpose of risk-based inspection is to identify the risk drivers, verify the equipment is safe, and point to ways to mitigate the consequences of the release of hazardous chemicals. The mechanical integrity issue, involving inspection and testing, requires performing inspection and tests on process equipment following recognized and generally accepted good engineering practices (commonly referred to as RAGAGEP). The frequency of inspection and tests of process equipment must be consistent with, good engineering practices, and prior operating experience. All of these should be considered in a risk-based inspection analysis.

Each company establishes and defines a plan for their mechanical integrity inspections and tests. The plan must address:

1. Type of inspection and tests to be performed,
2. The extent of inspections and tests,
3. The frequency or intervals of inspections and tests,
4. The preparations required,
5. The personnel qualifications and responsibilities, and
6. The acceptance criteria.