A three-phase approach for the design, development and implementation of mechanical integrity (MI) has been developed. Phase I includes reviewing a company's existing MI program and associated procedures and enhancing or designing the mechanical integrity program to match the needs of the company. Phase II includes the development of the MI program. Phase II activities involve identifying and prioritizing covered process equipment as well as developing inspection and testing plans and procedures, inspection forms, and equipment deficiency reports. A MI program manual is written which establishes the framework for the administration of the MI program. This manual covers written procedures, training for process maintenance activities, inspection and testing, equipment deficiencies, quality assurance, and program execution. Phase III includes assisting with the implementation of the MI program. The activities involve identifying, evaluating, and selecting inspection and testing contractors, scheduling baseline inspections and tests, evaluating inspection and test results, coordinating implementation of CMMS (Computer Maintenance Management System), and auditing the MI system for compliance with the OSHA 1910.119 regulation. This paper covers the fundamental elements of establishing an effective MI program and provides guidelines on how to avoid common and costly mistakes and pitfalls when implementing what has been considered the most difficult of OSHA's Process Safety Management (PSM) elements.
This three-phase approach furnishes a company with an effective tool for designing, developing and implementing a MI program that will not only be in compliance with the OSHA 1910.119 regulation, but will provide a vehicle for maintaining process, production, and facility equipment in a reliable and safe operating condition. This in turn equates to the protection of employees, the public, and the environment while reducing the costs of hazardous and unexpected downtimes or turnarounds due to failing or inappropriately maintained equipment.
Mechanical Integrity is defined as the program or activities which ensure that equipment in a specified process is designed, constructed, installed, and maintained to minimize the risk of accidental release of highly hazardous chemicals. Many of these activities are performed as part of a plant's maintenance program. Federal regulations have included these types of activities for their defined covered processes under the OSHA Process Safety Management Regulation (29 CFR 1910.119) and the EPA Risk Management Programs Regulation (40 CFR Part 68). Implementation of the mechanical integrity element of the PSM and RMP regulations is considered the most common struggle for companies whose processes fall under these standards.
Mechanical integrity is a key part of OSHA's PSM regulation. Combined with the Process Hazards Analysis, Mechanical Integrity forms the keystone for the arch of employee protection provided by all 14 PSM elements as seen in Exhibit 1 below. The foundation of the arch lies in the Documentation Control/Access and Management Commitment concepts of the PSM regulation.
