Process Safety Management & Mechanical Integrity

Regulations defining Process Safety Management (PSM) are quite extensive, but for use in this article we will refer to them as the "Elements of Process Safety Management". The elements of PSM interact with one another and are dependent upon each other. In other words, it is not possible to meet the requirements of one of the elements without considering its effect on the others. PSM programs typically include about a dozen major elements. The OSHA standard, the one most companies in the United States follow, contain fourteen.

This article focuses on the Mechanical Integrity element. Mechanical Integrity is the most frequently cited element for violation by OSHA inspectors performing audits of plant sites.

OSHA lists, regulates, and publishes information on Highly Hazardous Chemicals. If plant sites use these listed chemicals and the quantities of these chemicals exceed the listed thresholds set by OSHA, then the process utilizing them become "process critical" and must be covered by a Mechanical Integrity program.

A Mechanical Integrity program seeks to ensure that all equipment, piping, instrumentation, electrical systems and other physical items in a unit, system or process in that unit are designed, constructed and maintained to the appropriate standards, and the chance of failure of one of these systems is minimized by inspections that use appropriate techniques and frequency for the system.

Mechanical Integrity receives considerable attention because of the time, expense and resources required to implement these systems. An integral part of a Mechanical Integrity Program is a Process Hazard Analysis or a PHA. PHA's must be performed prior to proceeding with the program. The PHA will determine which of the parts of the plant are "process critical" and must be included in the program. The program usually is managed within a software based system on a computer or a network at the facility utilizing the system. The software program must be set up to store the required equipment history and corrective actions taken to meet current regulations.

Most professional managers in industries today are familiar with Mechanical Integrity Systems and their function. Often the initial setup and integration of these systems is performed by Qualified Contract Specialists that can streamline the implementation and make the programs easily understood, and in the case of an audit, ensure compliance.

These Qualified Specialists can also implement programs that show what equipment needs to be tracked and the recommended frequencies of that inspection. These programs can also include factory recommendations, ASTM and API recommended inspection methods. Part of the initial setup of the program is gathering the required information and presenting it in a logical manner for all the processes, vent systems and utilities of an integrated plant site, without voids in any functional systems.

Once the Mechanical Integrity Program is properly implemented, and if a compliance audit were to occur, the auditors will have access to up to date manuals developed for his/her review. These manuals show the processes using Engineering Flow Diagrams and what required items are included in the critical systems. The required items also have their risk prioritized. They also develop control documents to keep the system current both in the hard copy manuals and in the computer systems.

Many resources such as books and software systems are available to managers to ensure compliance with this element of Mechanical Integrity. Implementation in a timely matter normally requires multiple resources.