PSMS MOST COMMON STRUGGLE - IMPLEMENTING MECHANICAL INTEGRITY

Most companies have found that of the 14 OSHA PSM elements, Mechanical Integrity (MI) presents the greatest implementation challenge. Althou gh maintenance departments have successfully installed, repaired, and replaced plant equipment of decades, many of these same maintenance de partments have struggled with OSHA's PSM requirements. One major chall enge is prioritizing resources. Opportunities to improve will always e xist; however, it is often difficult to effectively allocate money and manpower. Another challenge is simply getting organized. The MI progr am should be supported by appropriate, useful procedures; but given th e multifaceted and ever-changing nature of maintenance, what procedure s should be written? How detailed should the procedures be? With nearl y 3 years of PSM of enforcement complete, an analysis of OSHA's MI cit ations helps to provide insight to these challenges. This paper presen ts ideas for implementing MI in a manner that meets OSHA's expectation s while contributing to safe, effective maintenance in PSM-covered pro cesses. In particular, the paper presents ideas for developing MI prog rams that effectively prioritize company resources, with appropriate i nspection/test/preventive maintenance and quality assurance (QA) activ ities. This paper also presents ideas for developing a list of mechani cal integrity procedures to address OSHA's requirements as well as the type of information to include in those procedures.