1. Course Material Overview of Process Safety Compliance with Standards
Process Hazard Analysis
Standard Operating Procedures
Safe Work Procedures
Mechanical Integrity
Management of Change
Auditing Process Safety Systems
Emergency Response Procedures
This training on process safety was developed by the Center for Chemical Process Safety (CCPS), which is a Technology Alliance of the American Institute of Chemical Engineers. It was developed under an OSHA “Susan Harwood Grant”. We have just completed Module 5 on “Safe Work Procedures.” This sixth of nine modules is entitled “Mechanical Integrity”.
This material was produced under grant SH F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor.
It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government

2. Process Safety Management for Biofuels
6. Mechanical Integrity
29 CFR (j)(4)
This material was produced under grant SH F-36 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.
Mechanical Integrity is a programmed implementation of activities to ensure that critical equipment will be suitable for its intended application throughout the life of the process. Mechanical Integrity systems are required by OSHA’s Process Safety regulations, which are referenced in this PowerPoint slide.

3. Catastrophic explosion in Mexico City November 19, 1984
Six hundred people were killed and 7,000 injured from an explosion following the failure of containment at a Mexico LPG facility in November, The storage facility contained four 422,000 gallon spheres of LPG. A line corroded over time and eventually failed. The spilled propane filled the concrete dikes, overflowed, found an ignition source, and exploded. The explosion damaged other spheres, triggering more explosions. Twelve cylindrical tanks were also damaged, some rocketing over 3,000 feet away. The blast was felt over 12 miles away.

4. Reference: “Incidents That Define Process Safety”; AIChE/CCPS; Wiley, 2008
Investigation of this incident was nearly impossible, since every employee of the terminal was killed. However, physical evidence pointed to wide spread corrosion and failure to identify and replace corroded equipment and piping as the main cause of the incident.

5. Mechanical Integrity
According to information published in 2003 by Marsh Insurance, approximately 46% of the largest insurance losses in chemical, petrochemical, petroleum refining, and natural gas processing facilities from 1972 to 2001 were due to a failure in mechanical integrity programs.
Copyright 2003 Edward E. Clark/Starr Technical Risks Agency, Inc.

6. Mechanical Integrity – Piping Systems
The average cost of a mechanical integrity program failure in the group of 100 accidents studied by Marsh was $84 million in 2001 dollars. This was physical damage only and did not include lost production or other costs. When these 100 largest and most costly losses were categorized by equipment type, piping failures represented the largest category; approximately 65% of the Mechanical Integrity losses involved piping failures. Piping failures are also the largest category of Mechanical Integrity losses in small plants.
Copyright 2003 Edward E. Clark/Starr Technical Risks Agency, Inc.

7. Mechanical Integrity
OSHA (j)
“The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.”
In addition to the economic and human cost of failed Mechanical Integrity programs, OSHA’s Process Safety regulations require a Mechanical Integrity program for equipment that is critical to the safe operation of the process. This includes the following types of process equipment:
Pressure vessels, heat exchangers, storage tanks;
Process piping systems (including piping components such as valves);
Relief and vent systems and devices (relief valves, rupture discs, etc.);
Emergency shutdown systems;
Controls (monitoring devices, sensors, alarms, interlocks) ; and
Pumps, compressors, blowers, agitators.
While OSHA’s PSM regulation may not apply specifically to your facility, the regulation is recognized good engineering practice and should be implemented at your facility to improve process safety.
In addition, fire protection systems, containment systems, mitigation systems, and utility systems should also be protected by the plant’s mechanical integrity system.

8. Mechanical Integrity Program
Ensures proper design, fabrication, and installation for new equipment
Designates equipment included in the program
Prioritizes equipment
Plans maintenance
A successful Mechanical Integrity program will include the following activities:
Ensuring that equipment is designed, fabricated, procured, installed, operated, and maintained in a manner appropriate for its intended application,
Clearly designating equipment included in the program based on defined criteria,
Prioritizing equipment to help plant management optimally allocate resources (e.g., personnel, money, storage space), and
Helping a plant staff perform planned maintenance and reduce the need for unplanned maintenance.

9. Mechanical Integrity Program
Recognizes equipment deficiencies
Incorporates recognized and generally accepted good engineering practices
Inspects, tests, and performs preventive maintenance
Maintains service documentation
A successful Mechanical Integrity program also:
Helps a plant staff recognize when equipment deficiencies occur and includes controls to help ensure that equipment deficiencies do not lead to serious accidents,
Incorporates recognized and generally accepted good engineering practices (RAGAGEPs),
Helps ensure that personnel assigned to inspect, test, maintain, procure, install, decommission, and re-commission process equipment are appropriately trained and have access to appropriate procedures for these activities, and
Maintains service documentation and other records to enable consistent performance of preventative maintenance activities and to provide accurate equipment information to other users, including other process safety and risk management elements.

10. Mechanical Integrity 1. New Plants & Equipment
New plants and new equipment should be covered by a Mechanical Integrity program. OSHA states, “In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions.”
This covers fabrication, installation, and startup of new equipment.

11. Mechanical Integrity 2. Equipment Selection
Not only will a robust Mechanical Integrity system add years to the life of critical equipment, it will also ensure that the equipment is available and functional when needed. As this picture of an antique car illustrates, a dedicated Mechanical Integrity program can add many years of life to a piece of equipment.
Earlier, on slide number seven, we mentioned different types of equipment that should be included in a Mechanical Integrity program. The equipment on the Mechanical Integrity list should be documented. Also, the rationale for the equipment being on the Mechanical Integrity list should be documented in order to preserve corporate memory.
The equipment list should be kept current with the plant’s Management of Change system.

12. Mechanical Integrity 3. Testing and Planned Maintenance
Once the critical equipment list has been designated and documented, a proactive inspection, testing, and preventive maintenance program (ITPM) should be implemented to prevent or predict failure of the critical assets. Planned maintenance is a much safer alternative than the “run to failure” maintenance mode.
OSHA requires that the inspection and testing program for process equipment follow “recognized and generally accepted good engineering practices.” This practice is sometimes called by an acronym, RAGAGEP.
“The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.”

13. Mechanical Integrity 4. Equipment Deficiency
OSHA requires that “The employer shall correct deficiencies in equipment that are outside acceptable limits before further use.” Any equipment deficiencies should be addressed as soon as possible after the deficiency is discovered. This will prevent failure of critical equipment and a subsequent hazardous release.

14. Recognized and Generally Accepted Good Engineering Practice
Mechanical Integrity
5. RAGAGEPs
Recognized and Generally Accepted Good Engineering Practice
OSHA’s PSM rule requires facility owners to document that their equipment complies with Recognized and Generally Accepted Good Engineering Practices, known by the acronym RAGAGEP. Whether your facility is covered by OSHA PSM regulation or not, you should understand the relevant RAGAGEPs to determine the appropriate mechanical integrity practices.

15. RAGAGEPs
API ASME ISA
Several organizations publish standards and guidelines which can be the basis for establishing your mechanical integrity RAGAGEPs. Three of the common organizations are:
American Petroleum Institute (API),
American Society of Mechanical Engineers (ASME), and
International Society of Automation (ISA)

16. Mechanical Integrity API 650
When evaluating RAGAGEP for your atmospheric storage tanks, it is best to consider the API 650 standard for vertical atmospheric tanks. API 650 applies to carbon steel or stainless steel tanks up to 14 feet diameter and up to seventy feet high, in non-refrigerated service that have a maximum design temperature of 200°F or less.

17. Mechanical Integrity ASME
When evaluating RAGAGEP for your pressure vessels, it is best to consider ASME Section VIII for design, fabrication, inspection, testing, and certification of fired or unfired pressure vessels operating at pressures exceeding 15 psig. Such vessels are used for containing chemical reactions and for storage of chemicals above atmospheric pressure.

18. Mechanical Integrity ISA
When evaluating RAGAGEP for your safety instrumentation, control systems, and safety instrumented systems, it is best to consider the ISA standards. ISA develops standards; certifies industry professionals; provides education and training; publishes books and technical articles; and hosts conferences and exhibitions for automation professionals.

19. Mechanical Integrity 6. Training
Training is required for mechanical integrity maintenance activities.
OSHA states, “The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.”

20. Mechanical Integrity 7. Documentation
The employer should document each inspection and test that has been performed on process equipment.
The documentation should identify:
the date of the inspection or test,
the name of the person who performed the inspection or test,
the serial number or other identifier of the equipment on which the inspection or test was performed,
a description of the inspection or test performed, and
the results of the inspection or test.

21. Mechanical Integrity 8. Training
Example of a Mechanical Integrity maintenance training guide
Mechanically Sealed Pump
The above link will take you to a hypothetical example of a Mechanical Integrity training guide for a mechanically sealed pump. Note the detailed information required on the form.
Reference: “Guidelines for Mechanical Integrity Systems”
AIChE/CCPS; Wiley, 2006; Appendix, Chapter 5 Resource Material, “Sample Training Guide”.

22. Mechanical Integrity 9. Maintenance & Spare Parts
“Replacement in Kind”
A good spare parts inventory and replacement system for those parts used in maintaining the equipment is another necessary component of an acceptable Mechanical Integrity program. OSHA requires replacement parts to be “replacement in kind”. OSHA defines “replacement in kind" as meaning a replacement which satisfies the original design specification. If the part is not a “replacement in kind”, than a “Management of Change” should be conducted. We will study “Management of Change” in detail during the next module, Module Seven.

23. Mechanical Integrity Benefits
1. Improved equipment reliability 2. Reduction in equipment failures 3. Improved product consistency 4. Improved maintenance consistency and efficiency
Reasonable expectations of a well organized Mechanical Integrity program include:
Improved equipment reliability
Reduction in equipment failures that lead to safety and environmental incidents
Improved product consistency
Improved maintenance consistency and efficiency

24. Mechanical Integrity Benefits
5. Reductions of unplanned maintenance 6. Reduced operating costs 7. Improved spare parts management 8. Improved contractor performance 9. Compliance with government regulations
Reasonable expectations of a Mechanical Integrity program also include:
Reductions of unplanned maintenance time and costs
Reduced operating costs
Improved spare parts management
Improved contractor performance
Compliance with government regulations

25. Mechanical Integrity Benefits
Looking at the nine benefits that we listed for a good Mechanical Integrity program, one can see that a good Mechanical Integrity program not only prevents incidents, but it also reduces operating cost, increases productivity, and increases profit.

26. Remaining Course Material
Overview of Process Safety
Compliance with standards
Process Hazard Analysis
Standard Operating Procedures
Safe Work Procedures
Mechanical Integrity
Management of Change
Auditing Process Safety systems
Emergency response procedures
We have just completed the module on “Mechanical Integrity”.
This training module was the sixth of nine modules contained in this course. The screen shows all nine modules. Our next module will discuss “Management of Change”.