An employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and must address the steps for each operating phase; operating limits; safety and health considerations; and safety systems and their functions. (See 29 CFR 1910.119(f) for full details on these elements.)
Mechanical Integrity (MI)
It is a priority of the PSM standard to maintain the mechanical integrity (MI) of critical process equipment to ensure it is designed and installed correctly and operates properly. Such MI requirements apply to the following equipment:
- Pressure vessels and storage tanks;
- Piping systems (including piping components such as valves);
- Relief and vent systems and devices;
- Emergency shutdown systems;
- Controls (including monitoring devices and sensors, alarms and interlocks) and;
Of particular interest to us here at Bacharach is the “controls” part of the Mechanical Integrity section, which is clarified as “including monitoring devices and sensors, alarms and interlocks” (29 CFR 1910.119(j)(v)). This is because our ammonia refrigerant detectors and monitors, like the MGS-400 Gas Detection Series, are applicable.
Engineered for use in cold storage facilities, MGS-400 gas detectors feature ammonia-specific sensors and are flush mounted in the enclosure to optimize the response time. For instance, when ammonia is detected, the leak detectors integrated audio/visual alarms alert personnel to the leak.
Now, to get back to the point, an employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Inspection and testing must be performed on process equipment, following recognized and generally accepted good engineering practices.
An employer must certify that they have evaluated compliance at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.
It is important to determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
The two most recent compliance audit reports should be on-hand.