This article was originally posted on Wednesday March 20, 2019
For about 25 years companies have been trying to answer two major questions about mechanical integrity compliance: What do we need to do in order to comply; and where do we start on the road to compliance? To answer these questions we must start with an understanding what mechanical integrity compliance consists of. Only then can we begin to formulate answers to these important questions.
Mechanical Integrity Compliance Defined
The CALARP (California Accidental Release Prevention) document defines mechanical integrity compliance as the task of ensuring that all process equipment is fabricated from the proper materials. This also includes proper installation, maintenance, and replacement of damaged equipment in order to prevent failures and accidental releases. One interesting item we can glean from this particular definition is that mechanical integrity compliance, if it is going to be implemented thoroughly, should include the entire life cycle of all assets involved in the program.
What This Means For Your Company What this means for you is that your primary consideration should be Risk Based Inspection (RBI) and Non-Destructive Testing (NDT) activities during the design and installation of your equipment. Sentinel can implement an RBI study in order to determine the proper metallurgy and help eliminate damage mechanisms before the asset is ever placed in service. We can also use predictive inspection strategies to identify the proper location for corrosion probes in the asset to keep you aware of its current condition.
There Is A General Standard Mechanical integrity compliance can include slightly different guidelines based on your geographic region or the particular industry your company is involved in. The common goal of federal, state and local authorities is that companies within their jurisdiction comply with the industry’s good engineering practices and emphasize the need to maintain auditable mechanical integrity compliance to their employees. In most regions focusing on compliance with OSHA 1910 through the execution of the API In-Service Inspection Codes (510, 570 and 653) is the perfect solution to ensure your company is following good mechanical integrity compliance policy.
How Sentinel Integrity Solutions Can Help
Sentinel provides support in three key categories that make up our Mechanical Integrity Compliance program:
Sentinel can help you define and then build any of these key elements into your MI program. We can provide an analysis that will help you determine what procedures and policy you need to implement in your organization. We can also help you train your employees to follow your mechanical integrity compliance policies, making them more valuable to your company. Through the use of software solutions we can help you streamline your MI program, making it more effective and efficient.
Why We Chose Our 3 Key Areas Of Focus
People - Sentinel believes that the key to any successful MI program is having the right people in the right roles; from Inspection and Maintenance to Process and Materials Engineering choosing the right person for the job ensures your company runs smoothly and safely.
Procedure - With the right people in place Sentinel can help you design a fully customized plan of action to help ensure you are in full compliance. This process could include elements like identifying covered processes, personnel training, written procedures and identifying which codes and standards you are required to comply with.
Software Solutions - With the trained personnel and procedures in place can you begin to implement an industry solution that streamlines your process, making your company more efficient.
If we consider the top categories cited in the OSHA NEP National Emphasis Program audits we find; Mechanical Integrity(MI), PSM (Process Safety Management) Procedures/Documentation, PHA (Process Hazard Analysis) Procedures/Documentation, Operations Management and Training Procedures/Documentation. With specific subcategories of: PSI RAGAGEP, MI Written Procedures, MI Inspections and Testing Performed.
Training And Documentation Are Vital To MI
FACT: The top five categories listed above represent 80% of the findings in mechanical integrity compliance audits. This makes it clear that negative findings are primarily addressing gaps around the people and procedures. This indicates that facilities either don’t have proper documentation of their trained individuals, or they don’t have the necessary documentation to support their work flow processes.
How Sentinel Can Help You
Sentinel Integrity Solutions’ Mechanical Integrity Solution is designed to support those closest to the work process. Our program provides an auditable process from start to finish, all while helping you focus on a compliance driven workplace.
It is important that mechanical integrity compliance programs address both a time-based and risk-based approach. Whether you are implementing a risk-based solution, or sticking with a time-based approach, there are essential elements that must be included in your program.
The following is a definition of damage mechanisms and inspection strategies/plans.
According to API 510 188.8.131.52, “The inspection plan is developed from the analysis of several sources of data. Equipment shall be evaluated based on present or possible types of damage mechanisms. The methods and the extent of NDE shall be evaluated to assure they can adequately identify the damage mechanism and the severity of damage. Examinations must be scheduled at intervals that consider the Type of damage, Rate of damage progression, Tolerance of the equipment to the type of damage, d. Probability of the NDE method to identify the damage and Maximum intervals as defined in codes and standards.”
API 570 has similar wording in section 5.1.1. Sentinel can help by facilitating a damage mechanism review to help identify the potential damage mechanisms an asset may be susceptible to and by defining a strategy for detecting damage to those mechanisms.
According to API 580 Section 16.8, “One of the most important aspects of managing risk through RBI is the development and use of mitigation strategies.” It is no longer acceptable to inspect all assets as though they are the same, or as if they were exposed to the same damage mechanisms. We implement a custom inspection that ensures your equipment is safely operating within the bounds of mechanical integrity compliance standards.
How You Can Be Sure You’re In Compliance
Routine evaluation of all three parts (people, procedures, and software solution) of your Mechanical Integrity Program will not only help you stay in compliance, it will also help you determine if you are getting true value from your current approach to MI.
Sentinel believes you can ask yourself a two key questions to assess the effectiveness of your MI Program;
Do I have the right people, and the right number of people, to support the current mechanical integrity program?
Do my inspection plans provide enough detail for the inspector or technician to perform the task thoroughly?
If you cannot answer yes to both of these questions without hesitation, then you may need to evaluate your current mechanical integrity compliance system and make some changes. Contact us here at Sentinel Integrity Solutions today and let us help you develop the perfect plan for your company.