Inspectioneering Journal

The Importance of Process Safety Information in Implementing a Mechanical Integrity Program

By Holly F. Baker at Baker Inspection Group, L.L.C. This article appears in the July/August 2013 issue of Inspectioneering Journal.


The Process Safety Management Rule (29 CFR 1910.119 - PSM) has long been recognized as a collection of interdependent requirements. In recent reviews of PSM programs by OSHA (“the agency”), it has been shown that two of the most cited elements in agency audits tend to be Mechanical Integrity and Process Safety Information (see chart below, from Federal OSHA’s Refinery National Emphasis Program (NEP) Report, Attachment “A”, which is the result of the first year of citations). These also happen to be the two elements that, in our experience, have proven to be the most difficult for which to develop and implement successful programs and to achieve a foundation for regulatory compliance. If compliance to mechanical integrity presents the most challenging issues to industry, we can believe that it must be related to issues with process safety information – the next most challenging element.

Chart from Federal OSHA
Chart from Federal OSHA's Refinery National Emphasis Program (NEP) Report, Attachment "A", which is the result of the first year of citations

If industry believes that their programs are working, at least in these two categories, apparently the agency disagrees. Mechanical Integrity alone accounted for nearly 30% of the citations. Why? In our experience, we believe there is a “disconnect” between organizations within a facility that may be in charge of Process Safety Information, and those who are in charge of Mechanical Integrity. Our message here is that compliance with Mechanical Integrity requires at least two categories of information that should be contained in a complete Process Safety Information program: 1) design information or basis, and 2) acceptance criteria. This information should then be a matter of clear communication between management, affected departmental resources, and document management systems.Process Safety Information (PSI) contains three sub-paragraphs: 1) “Information pertaining to the hazards of the highly hazardous chemicals in the process,” 2) “Information pertaining to the technology of the process,” and 3) “Information pertaining to the equipment in the process.” This article is intended to review each of these elements and discuss the effects they may have on Mechanical Integrity (MI), or in developing and implementing a Mechanical Integrity Program (MIP).

Consideration of Process Hazards

In our experience, the consideration of process hazards with respect to the development of MI programs has often been met with a discounted approach that either, fails to identify the connection, or reflects sensitivity regarding the proprietary nature of certain hazardous processes. Early in our attempts to develop MIP’s, requests for process hazards analyses (PHA’s) were often met with responses such as, “why do you need those to develop a MI program?” even though such documents by law should be readily available to anyone who may be working on the process. Over many years of developing MI programs, we have determined that one of the primary reasons for knowledge of process hazards in the development of MI programs is the setting of priorities. Considerations such as toxicity information, permissible exposure limits, reactivity data and corrosivity data are all valuable in the establishment of risk assessments that may be used to guide inspection and maintenance priorities from the perspective of consequences of failure.

An organization that is regarded as a premier provider of recognized and generally accepted good engineering practices (RAGAGEP), the American Petroleum Institute (API) came to this conclusion many years after the PSM Rule was promulgated. This conclusion resulted in the development of API 580, “Risk-Based Inspection,” or RBI. Although RBI remains a recommended practice, and not necessarily a code or standard, many of the conventions of RBI have been incorporated in other API documents that are recognized codes, including API 510 (Pressure Vessel Inspection), API 570 (Piping Inspection) and API 653 (Aboveground Storage Tank Inspection).

But where is the requirement for setting inspection and maintenance priorities? As with many of the performance based requirements of PSM, they lie in subtly worded phrases that are open to interpretation. Paragraph (j) (4) (iii) states, “The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.” At least one method of assuring compliance to this issue would be to set inspection priorities through a risk classification process. The establishment of inspection frequencies, which could reasonably come from the establishment of inspection priorities, can be based on risk classifications that consider consequences of failure from the process safety information that pertains to the hazards of the process.

This reasoning also applies to (j) (5), “Equipment Deficiencies.” Our experiences tell us that many owner / users have struggled with the phrase, “timely manner.” What does it mean? It has become clear over years of developing such programs that there is not a simple answer to this question, but it is definitely related to the establishment of maintenance priorities that must be based in part on the hazards of the process and the consequences of failure.

Regardless of whether an owner/user chooses to follow RBI or selects a more simplistic system for risk classification, ultimately the hazards of the process will come into consideration in the establishment of inspection and maintenance priorities.

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