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mwarrenasint
Explorer
Are you Process Safety Management Compliant?

 

In my previous blog “What is Mechanical Integrity”, I outlined how various codes and standards define and provide guidance on what should be included in a mechanical integrity program. In this post I would like to discuss, what it means to comply with these codes and standards?

Compliance means different things to different regions or may even vary within our organizations. A common thread that Federal, State and Local Jurisdictions have with operating companies is this notion of compliance with industry good engineering practices. Here in the US those RAGAGEPs (recognized and generally accepted good engineering practices) can typically be traced back to compliance with Occupational Safety and Health Administration (OSHA) 1910.119 which is OSHA’s PSM (Process Safety Management) regulation, specifically sub-part (j) if you want to skip down to just the mechanical integrity sections.

It is this regulation that makes PSM and mechanical integrity a “law”, meaning that it is not optional. While OSHA 1910.119(j) is a law here in the US it is worth noting that each region around the globe have similar laws, Australia’s Work Health and Safety (WHS) Regulations 2011, South Africa’s Occupational Health and Safety (OHS) Act, and the EU’s Seveso III Directive just to name a few.

Here in the US, we comply with these OSHA regulations, using the mechanical integrity example, through compliance and execution of the API (American Petroleum Institute) In-Service Inspection Codes (API 510, API 570 and API 653). It is worth noting that inevitably when talking about mechanical integrity the topic of Risk Mased Inspection (RBI) will come up. So, let’s briefly address the subject. Many people will state or imply that to be in compliance with RBI we must follow API RP 580 and/or API RP 581, however the “RP” in the code names indicate that they are a “recommended practice”. In fact, API RP 580 states in Section 1.2 that “Many types of RBI methods exist and are currently being applied throughout industry. This document is not intended to single out one specific approach as the recommended method for conducting an RBI effort.” Which takes us back to using our RAGAGEPs and documenting the process we have elected to use.

Let’s back up a bit, we have established that there are laws governing Process Safety Management of which mechanical integrity is just one part. So, how do we ensure we are in compliance with all aspects of these regulations. Many organizations start their process by performing a Process Hazard Analysis (PHA) which may be defined as;

A systematic and structured approach to identify and evaluate the potential hazards associated with a process and its equipment. It is typically conducted by a team of experts who analyze the process and equipment to identify potential hazards, their likelihood of occurrence, and the potential consequences of those hazards.

The purpose of a PHA is to identify potential hazards and evaluate the risks associated with them. The analysis helps to identify measures to reduce or eliminate the risks and to improve the safety and reliability of the process.

A PHA typically involves several steps, including:

  • Defining the process and identifying its components.

  • Identifying the potential hazards associated with each component.

  • Evaluating the likelihood and consequences of each hazard.

  • Identifying and recommending measures to control or eliminate the hazards.

  • Documenting the analysis and its findings.


The following is an example of a well-documented PHA.

Identifying the Hazards


Selecting Hazards


 

Evaluating the likelihood and mitigation


Calculating a Hazard Assessment


 

Ranking these risks for planning


Risk Matrix w/ Ranked Hazards


 

Having a well-documented process in place like this is key to ensuring compliance. Periodic audits should be performed to verify these PSM elements are being kept up to date as our equipment ages and to account for processes changes.

When is the last time you’ve updated and audited your PSM process? Are you performing various elements of PSM in a single platform? Are you able to compare your RBI results with the hazards and consequences defined in your PHA?

Please like and leave me a comment on this blog and let me know if you have questions as well as letting me know if there are other elements of PSM that you would like for me to cover in my next series of blogs.
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