Introduction
Everyone wants fewer leaks and failure of their equipment and piping; and most everyone has a lot of Fixed Equipment Mechanical Integrity (FEMI) programs in place to help with that objective. But in the 100+ site FEMI assessments that I have completed over the last few decades, I find very few sites that effectively use this one method to make substantial reductions in their piping leaks and failures. What is that method? It revolves around the effective use of “investigations” for leaks and near-leaks. Yes, most sites have a Process Safety Management (PSM) Program that makes sure bigger events (ones with higher real and potential consequences that get management attention) get investigated and action items are normally put in place to hopefully avoid a recurrence – at least for the next few years. But very few sites are applying simple, effective investigation techniques to lower the likelihood of repeat incidents from the smaller “non-events” or “near-leaks.” There’s a lot of PSM literature that clearly indicates that if we pay much more attention to these lower consequence leaks and non-consequential near-leaks, we can significantly reduce the likelihood of a bigger event in the future. That’s what this article is all about.
The FEMI Pyramid
As mentioned in the introduction, most sites have a documented investigation work process and most sites investigate big releases, fires, and some small leaks, etc. In the U.S. this is required by some regulations and just makes good sense from the standpoint of learning from the bigger events and preventing them in the future. But few sites do much of anything to investigate, document, and share the lessons learned from the smaller releases, leaks and near-leaks (L/NL). But my theory and reality has shown that if owner-operators pay more attention to the bottom of the FEMI Pyramid in Figure 1 below, they will experience fewer big FEMI events down the road. I derived this figure from the process safety pyramid which holds that the same thing is true for most process safety issues.

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