What is Mechanical Integrity?
OSHA Process Safety Management (29 CFR 1910.119(j)) and EPA Risk Management Program (RMP) Level 3 (40 CFR 68.73) define the Mechanical Integrity (MI) element as a systemized approach utilizing recognized and generally accepted good engineering practices (RAGAGEP), written procedures, and training to manage the on-going maintenance program and integrity of process equipment. EPA's RMP Program Level 2 Maintenance element (40 CFR 68.56) is almost identical in approach to the MI element and requires the facility to have a written maintenance program. EPA's RMP Program Level 1 does not require MI or maintenance programs, but you may want to consider implementing them as best practices relative to OSHA and EPA General Duty clauses.
How to Start Implementing MI
Achieving MI compliance begins with an assessment of the facility's equipment and maintenance records. The following equipment is required to be included in the MI program (29 CFR 1910.119(j)(1)(ii), 40 CFR 68.73(a)):
- Pressure vessels and storage tanks
- Piping systems (including piping components such as valves)
- Relief and vent systems and devices
- Emergency shutdown systems
- Controls (including monitoring devices and sensors, alarms, and interlocks)
Trinity can assist in developing an inventory of existing equipment, spare parts, and components for the covered process and utilizing existing resources to streamline this process. We are fluent in computerized maintenance management software systems (CMMS) such as MP2, Maximo, and SAP and can deliver optimized solutions working within the client environment.
Industry faces major MI enforcement and implementation hurdles to demonstrate that site-specific maintenance procedures, testing, and inspections comply with RAGAGEP for their covered process equipment and instrumentation. We facilitate a thorough review of original equipment manufacturer (OEM) manuals; codes such as API, ASME, IEEE, NFPA, and IIAR; and best practices drawn from industry trade groups and Trinity's experience providing MI services nationwide. We develop a site-specific MI program that meets your current requirements and includes a strategy to maximize efficiency for planned “downtime” for the process. Building unique preventive maintenance schedules that coordinate facility production schedules, learned component duty cycles, and OEM requirements poses a challenge that Trinity is well suited to address.
Our goal is to map existing maintenance procedures, work orders, and PM inspections to the MI standard and provide a document that identifies potential gaps and recommends the best path forward for an effective MI program.
Facility management is required to assure its covered processes are built, maintained, inspected, and tested consistent with design specifications, manufacturer's instructions, and RAGAGEP, and that spare parts are managed accordingly. Trinity's approach results in an MI program designed to satisfy these required assurances for maximized safety benefits and successful agency and internal triennial PSM/RMP compliance audits .
MI Support Services
PSM/RMP Covered Process Boundary Determination and Process Equipment Inventory
Understanding the PSM/RMP applicability boundary at your facility is crucial to properly implementing the MI standard. Common questions involve whether utility systems, such as process air or cooling water, fall under the MI standard, and each case should be evaluated against its location and importance to the covered process. Trinity will review your process operations and facility siting study to assist in determining an accurate, realistic approach for PSM/RMP boundaries.
Additionally, MI cannot be properly implemented without a full inventory of what constitutes the “covered process” equipment and instrumentation. Creating this database can be a daunting challenge, for legacy operations and greenfield construction alike. Our consultants are skilled in efficiently gathering field data and inventorying covered process equipment to identify the equipment that must be addressed in the MI program.
Trinity Consultants can provide data gathering and database management solutions for numerous purposes:
- Developing a comprehensive equipment and spare parts inventory for the covered process;
- Gathering and creating a database for technical data and specifications for covered process equipment;
- Labeling equipment as PSM/RMP MI in CMMS systems such as MP2, Maximo, or SAP; and
- Determining non-applicable equipment and documenting its basis for exclusion.
OEM and RAGAGEP Standardization
Greenfield construction, existing operations, and legacy covered process systems all require that the facility owners assure the equipment construction and inspection and testing programs comply with manufacturers' recommendations and code requirements, known as RAGAGEP. These OEM manuals, standards, and best practices must be compiled and identified for each piece of equipment in the covered process.
An OSHA or EPA auditor may ask the facility maintenance department for specific PMs and the site's documentation demonstrating that those PMs are following RAGAGEP. Auditors will scrutinize the PM frequency, methodology, and tools, parts, and labor used against their expectations, derived from OEM/Code documents, historical MI implementation, field data, previous audits, and agency publications. Trinity Consultants is experienced in navigating the immense database of RAGAGEP information and providing a roadmap for compliance success.
Maintenance Procedures Technical Writing
The PSM/RMP MI standard requires covered processes to have “written procedures” for maintaining the integrity of process equipment. While many facilities have a CMMS implemented with a dedicated PM or work order system in place that defines routine maintenance tasks and activities, we often find that these work orders do not fully address the MI written procedure requirement. For facilities that do not utilize a CMMS for work orders, there is usually an even larger compliance gap for maintenance procedures.
Trinity will provide your facility with the following documents that comply with PSM/RMP requirements:
- Written MI Administrative Program
- Written MI Inspection and Testing Procedures that follow RAGAGEP
- Written MI PM procedures for on-going integrity management
Trinity Consultants has developed full written MI programs for a wide range of facilities and we have established industry best practices and standards in our approach.
Trinity Can Help
Trinity Consultants leverages its combined environmental, safety, and process engineering experience to create comprehensive and well-managed PSM and RMP maintenance solutions. Our nationwide consulting staff has a generous database of best practices, lessons learned, and OSHA/EPA auditing experience to ensure we continuously add value to your process safety systems.
Contact Trinity Consultants today at (800) 229-6655 to start the discussion about your process safety maintenance programs.