For those managing a covered process such as an ammonia refrigeration system, mechanical integrity (MI) tends to require the most frequent upkeep of all the 14 elements of PSM. MI activities come in all shapes and sizes: some daily, some every 5 years—some inexpensive, some costly. But if the whole point of the PSM program is to keep the chemical in the pipes, keeping your system in good functioning order is essential. Here is an overview of the mechanical integrity requirements found in Title 40 CFR §68.73 and Title 29 CFR §1910.119(j):
The mechanical integrity section outlines the requirements for maintaining the mechanical integrity of process equipment in a facility. It specifies the application of the regulations to various types of equipment such as pressure vessels, piping systems, relief systems, and emergency shutdown systems. The regulations emphasize the need for written procedures for equipment maintenance, training for employees, regular inspection and testing, addressing equipment deficiencies, and ensuring quality assurance in construction, installation, and spare parts. Of these subjects, inspection and testing, and addressing equipment deficiencies are the most important for most facilities.
There are four key components to inspection and testing of process equipment:
Inspections and tests must be performed on process equipment.
The procedures for inspections and testing must follow recognized and generally accepted good engineering practices (RAGAGEP).
The frequency of inspections and tests should be consistent with manufacturers' recommendations, good engineering practices, and may be increased based on prior operating experience.
Documentation of each inspection and test is required, including the date, the person who performed it, equipment identifier, description of the inspection or test, and the results.
Consider the following requirements related to equipment deficiencies:
inspection and testing of process equipment. It outlines four key components:
It states that the facility is responsible for correcting any deficiencies in the equipment that are outside acceptable limits, as defined by the process safety information. For example, if you have a pressure vessel with a minimum design metal temperature (MDMT) of -20°F which is operating at -23°F, this would need to be corrected.
These deficiencies should be corrected before further use, or in a safe and timely manner when necessary means are taken to assure safe operation. This means that any issues with the equipment that could impact its safe operation should be addressed promptly to maintain the integrity of the process equipment.
If you're looking for a 5-year mechanical integrity audit (MIA), annual IIAR 6B inspections, or other mechanical integrity resources, submit a request through our contact page.
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