RC-PSM-PCY-30-0008

POLICY
EQUIPMENT INTEGRITY POLICY

REV. 1
07-OCT-2012
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TABLE OF CONTENTS

1.

INTRODUCTION................................................................................................ 2

2.

SCOPE / PURPOSE ............................................................................................ 2

3.

DEFINITIONS ..................................................................................................... 3

4.

EQUIPMENT INTEGRITY REQUIREMENTS ............................................. 4

5.

RESPONSIBILITIES .......................................................................................... 9

6.

REFERENCES ................................................................................................... 10

Rev.

Issue Date

Amendment Description

0
1

01-Jul-2009
07-Oct-2012

First Release
Periodic review / Approver Change/Formatting changes

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Prepared
By:
KK/MT
KSK

Chkd
By:
RC
MVT

Apprd
By:
RGY
ABM

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1. INTRODUCTION
This policy defines the requirements concerning RLOC s commitment to meet
the Occupational Safety and Health Administrations, (OSHA), Process Safety
Management (PSM), regulations.
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2. SCOPE / PURPOSE
The intent of this document is to establish what standards/activities are required
on Process Equipment to reduce/prevent the risk of a potential unsafe situation
through an uncontrolled release of hazardous chemicals. While this document
may be considered generic, more specific details of how this policy is executed
/enforced are found in the Equipment Integrity Manual, RC-PSM-MNL-30-0002.
The requirements set forth in this document are based on OSHA PSM
regulation CFR 1910.119 (j) Mechanical Integrity and Q-Chem Operational
Excellence program, Element 3.8, Incident Prevention, Quality, and Reliability.
This document applies specifically to the following equipment types/systems.

Pressure Vessels
Tanks
Piping Systems
Relief and Vent Systems
Pumps, Compressors, and Drivers
Fired Heaters and Boilers
Heat Exchangers
Fire Protection Equipment/Systems
Controls and Emergency Shutdown Systems
Electrical System Equipment
Critical Buildings and structures

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3.

DEFINITIONS
Maintenance

Activity to retain or restore equipment to an acceptable

condition through Inspection and Testing based on
Company, Industry Code, Manufacturer / OEM
requirements and/or industry best practices.

Inspection

Activity whereby an equipment and/or its components

condition is observed and documented and then
compared
against
Company,
Industry
Code,
Manufacturer requirements, and/or industry best
practices for acceptance. Examples of this type of
activity include the following.
Corrosion (visual and thickness measurement)
Shaft tolerances
Electrical connector thermography
Venturi flow orifice installation

Testing

OE
PSM
MOC
PSSR
PHA
QA

QC

Activity whereby equipment physically and/or its

response to specific conditions is measured against
Company, Industry Code, Manufacturer requirements,
and/or industry best practices for acceptance. Examples
of this type of activity include the following.
Over Speed Test of mechanical governors
Calibration check of process analyzers
Hydrostatic test of process equipment/piping
Uninterruptible Power Supply load/time measurement.
Operational Excellence
Process Safety Management
Management of Change
Pre-Startup Safety Review
Process Hazards Analysis
Quality Assurance, The planned and systematic activities
implemented in a quality system so that quality
requirements for a product or service will be fulfilled.
The observation techniques and activities used to fulfill
requirements for quality.

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4.4

EQUIPMENT INTEGRITY REQUIREMENTS

Equipment Integrity is accomplished through QA and QC documents/activities
focused on the type of equipment such as that defined in Section 2 of this
document, the different stages of a piece of equipments existence as well as
general practices to identify/rectify equipment problems. These specific and
general points to address are defined as follows.

4.1

Equipment Integrity Program Defined

As a first step to establishing an effective Equipment Integrity Program, a
categorized list shall be compiled to identify specific process equipment that
will be held to the requirements defined in Sections 4.2 and 4.3 below. An
Equipment Integrity Application Process shall be utilized to identify equipment
included in the program with criteria based first on the equipment types listed
in Section 2 of this document and second on the results of failure/release as it
relates to safety and environmental impact. Process Equipment shall be
considered in the program until determined otherwise by the Equipment
Integrity Application Process.

4.2

Specific Areas of Emphasis

4.2.1

Design
The Design phase is the first step in an equipments life. During this phase
information from different sources shall be used to ensure equipment can
contain the product being handled and can be operated/maintained reliably.
Equipment design shall be based on Company and Industry Codes and
standards. Where Company and Industry Codes and Standards do not exist
or apply, industry recognized and accepted good engineering practices shall
be utilized.
PSM element, Management of Change, shall be used to coordinate design
changes along with new additions as a means to ensure proper reviews are
conducted with subject matter experts prior to implementation. The MOC
element applies not only to entire engineered equipment such as pumps,
compressors, etc. but also individual components such as the mechanical
seal and bearings with respect to Equipment Integrity.
Design documentation requirements shall follow PSM element Process.
Process Hazards Analysis, shall be conducted as part of the design process
as applicable, to identify the correct level of process control.

4.2.2

Purchasing/Contracting
Purchasing requirements based on the equipment types identified in Section
2 of this document along with items at the component level such as bearings,
chemicals, etc. shall be utilized as part of an overall Material Purchase,
Verification, Storage, and Handling Guideline. The emphasis being on the
front end during material selection to prevent errors as well as establish
material/equipment requirements through documented specifications as
necessary.
Contractor acceptance criteria/performance reviews as defined in PSM
element shall be used to manage contractor performance and ensure
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contractor work is conducted safely while on-site as well as complies with

defined quality control/assurance requirements.
4.2.3

Fabrication/Construction
Quality Control/Assurance requirements as part of a standard and/or specific
to the job such as part of the Scope of Work shall be used to assure proper
materials of construction are used, personnel are qualified, controlled work
practices (welding, bolting, torque, lubrication, etc), as well as work is
conducted in accordance with the Design requirements.

4.2.4

Receiving
Receiving inspection plays an integral part of the overall Material Verification
and Storage Guideline as mentioned in Section 4.2.2 of this document.
Standard receiving inspection requirements shall be put in place including
Positive Material Identification, Material Certification, Test Certificates, etc. to
assure material received is as per the original order.
Receiving inspection requirements shall include off-site activities and verified
using Quality Assurance plans both formal and informal.
Material not meeting established/defined requirements shall be registered as
a Non-Conformance as per Section 4.3.3 of this document.

4.2.5

Storage and Handling

Material/Equipment used in the original construction as well as repair of
existing equipment shall be stored and handled as per Company and/or
Manufacturer standards. This is necessary to assure material such as piping;
gaskets, chemicals, etc. do not degrade and become unacceptable for use or
present an unsafe situation. Material/Equipment storage program shall also
include provisions for addressing items having a shelf life.

4.2.6

Installation/Startup
Installation/Start-up is fundamentally affected by and addressed by the same
points identified in Fabrication/Construction, Section 4.2.3, above.
A Start-up control point review for any new addition or modification shall
utilize PSM elements, MOC, PSSR.

4.2.7

Operation
Safe/continued operation of process equipment requires that the operation
stays within the design limits of equipment as well as the equipment condition
understood.
Correct operation is accomplished specifically through
application of the following PSM elements and practices.
Correct operation includes the application of chemicals, additives, and
gases introduced into the process during the course of operating the unit.
Understanding the equipment condition along with maintaining the equipment
requires the timely execution of inspection and testing activities. Inspection
and testing activity content and frequency shall be based on Company, Code,
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and Industry accepted best practice along with consideration of Manufacturer

recommendations.
4.2.8

Maintenance
Maintenance activities\practices shall focus on planned events as opposed to
breakdown. As such, work order planning and execution controls shall be
established to ensure the QC/QA requirements are addressed prior to job
execution.
Quality control/assurance documentation/activities, including
documents typically referred to as Standard Maintenance Procedures, shall
be used as applicable to ensure the correct materials are used as well as the
job is executed and documented in accordance with Company and Industry
accepted best practice.
Personnel executing maintenance, inspection, and testing shall be
qualified\trained to conduct these activities.

4.3

General Areas of Emphasis

4.3.1

Equipment Deficiencies
Equipment deficiencies may be defined as any equipment condition, physical
and/or operating, that is not per design. These deficiencies may include
errors in the original manufacturing, construction, or repair as well identified
as the following for example.

Leaking mechanical seal

Instrument out of calibration
Excessive furnace tube temperatures
Excessive clearances in bearing installation

The important aspect of an equipment deficiency is to identify and

address/resolve it.
Everyone involved in Equipment Integrity have a
responsibility to take action when an equipment deficiency is encountered.
This action may be direct or indirect such as obtaining guidance/assistance
from others as referred in Tenets of Operation.
Methods, formal and informal, of addressing equipment deficiencies as they
arise include the following.

Operator Routine Duties/Rounds

Written communication in the form of a memo or email
Computerized Maintenance Management System Work Order
Management of Change
Pre-Startup Safety Reviews
Production/Maintenance Shift Turnovers
Process Hazards Analysis
Inspection Recommendations
Condition Monitoring (predictive tool)
Preventive Maintenance
Distributed Control System trending
Risk assessment and mitigation of parts/equipments which require
reliability improvement.
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4.3.2

Equipment History
Recording of equipment history is an important aspect of any integrity
program to identify problems/issues not immediately evident at the time of
repairs/failures as well as serve as reference for future works. Equipment
History shall be recorded to support the following activities.
Inspection activity completion verification
Repetitive Problem identification
Spare Parts needs

4.3.3

Non-Conformance
Material and/or activities not in compliance with established Company
requirements concerning Equipment Integrity shall be defined as NonConforming. A Non-Conformance system shall be used to identify and
address non-conformance issues through the use of action items, specifically
for improper material selection/delivery and quality control compliance.

4.3.4

Training
Personnel involved in Equipment Integrity shall be informed and trained as
necessary to ensure these individuals are qualified to perform the tasks per
the required procedures/practices. Training for Equipment Integrity activities
shall be based on the specific QC/QA documents and follow the requirements
established in the PSM element.

.
4.3.5

Auditing
Auditing is a necessary activity to ensure compliance as well as serve as a
means for review/continuous improvement. Compliance with this Equipment
Integrity Policy shall be accomplished per the following means.
i.

Quality Assurance
Quality Assurance Plans shall be utilized to verify compliance with
Company Quality Control and Industry Codes for the following equipment
types and/or activities.

Relief and Vent Systems

Fire Protection Equipment/Systems
Controls and Emergency Shutdown Systems
Mechanical Overspeed Trip Testing
Industry Code Required, Frequency Based, Inspection and Testing
Activities

The need and depth of Quality Assurance Plans for other equipment types as
identified in Section 2 of this document shall be decided on an individual
basis.

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ii.

Procedure/Practice Review
Each department will be responsible for routinely reviewing their
procedures and processes that support the Equipment Integrity program
to ensure they are functioning properly. The frequency of such review
shall be determined by the respective procedure/process department
owner unless dictated by the PSM Manual, QC-PSM-MNL-00-0001.

iii. Equipment Integrity Program Review

The equipment integrity program shall be audited for completeness /
effectiveness by internal Company audit a minimum of once (1) every three
(3) years.
Additional auditing such as external compliance audits shall follow the
requirements established in the PSM Manual QC-PSM-MNL-00-0001.
4.3.6

Failure Analysis
Breakdown Maintenance by definition is a direct result of equipment failures
and a time to be avoided based on the additional safety and integrity issues
that arise as opposed to planned maintenance. Equipment failures are to be
understood so as to learn from them and prevent their re-occurrence.
Failure\Root Cause determination shall be based primarily on the Why Tree
method of analysis. Additional methodologies may be employed depending
on the circumstances of the event.

4.3.7

Identification/Resolution of opportunities for improvement

Opportunities for Improvement not identified directly as a result of Failure
Analysis or Incident Investigation may present themselves through repeat
repairs or other repetitive actions. Identification and resolution of repetitive
problems is advantageous based on the following.

Reduces the likelihood of incidents by focusing on problem areas where

the chance of an incident is greater.
Makes good business senses from a cost/benefit basis to
reduce/eliminate repeat work.
Problems may have already occurred and solved somewhere else in the
system so the solution can simply be replicated.

RLOC shall utilize Reliability task force / Reliability improvement Team, to

identify and address Opportunities for improvement.

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5.

RESPONSIBILITIES
Department Head responsibilities shall be based on their involvement in
activities defined in this document. Primary ownership/responsibility of the
general areas mentioned in this document is defined as follows, with other
Departments providing a supporting role. Individual responsibility shall be
defined in the specific QC/QA document that supports this policy.

5.1.

Plant Manager / Deputy Plant Manager

5.2.

Maintenance Superintendent

5.3.

Responsible for Quality Assurance as it applies to activities conducted by

Production personnel.
Ensure Plant is operated as per design/within limits.
Follow operation section, 4.2.7 , of this document
Define the skill level required and ensure manpower resources are
properly trained and have the level of qualification/skill to execute
Production activities.
Identification/ Resolution of opportunities for improvement as per section
4.3.7 of this document
Follow Non-Conformance section, 4.3.3. of this document.

Responsible for Quality Assurance as it applies to activities conducted by

Maintenance personnel as well as Contractors under Maintenance
supervision/direction.
Define the skill level required and ensure manpower resources are
properly trained and have the level of qualification/skill to execute
Maintenance activities.
Maintain equipment history as per section, 4.3.2 , of this document (as it
applies to Maintenance activities).
Repair and maintenance as per section, 4.2.8 , of this document.
Identification/ Resolution of opportunities for improvement as per section
4.3.7 of this document
Follow Non-Conformance section, 4.3.3. of this document.

Technical Superintendent

Responsible for Quality Control as it applies to activities\work practices

conducted by Technical personnel as well as Contractors under Technical
supervision/direction.
Primary focus for conducting Quality Assurance as it applies to Equipment
Integrity activities.
Define the skill level required and ensure manpower resources are
properly trained and have the level of qualification/skill to execute
Technicals activities.
Follow Design section, 4.2.1, of this document.
Follow Fabrication/Construction section, 4.2.3, of this document.
Follow Installation/Startup section, 4.2.6, of this document (as it applies to
new and modified construction)
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5.4.

Follow Non-Conformance section, 4.3.3, of this document.

Responsible for failure analysis section, 4.3.6, of this document.
Responsible for Identification/Resolution of opportunities for improvement
as per section, 4.3.7, of this document.
Maintain equipment history section, 4.3.2, of this document (as it applies
to Industry Code Based Inspections)
Responsible to follow receiving section, 4.2.4, of this document (with
respect to off-site QA activities)
Follow operation section, 4.2.7, of this document (with respect to condition
monitoring/code based inspections)

Materials Manager
Responsible for Quality Control as it applies to activities conducted by
Material
personnel
as
well
as
Contractors
under
Material
supervision/direction.
Define the skill level required and ensure all employees are properly trained
and have the level of qualification/skill to execute Material Department
activities as per
Purchasing/Contracting section, 4.2.2, of this document.
Receiving section, 4.2.4, of this document (with respect to deliveries onsite)
Storage and Handling section, 4.2.5, of this document.

5.5.

HSE Superintendent
Responsible for Quality Assurance of Fire Protection Equipment/Systems.

5.6.

Head of Administrative Services

Responsible for Training section, 4.3.4, of this document.

5.7.

All Superintendents
Responsibility for addressing Equipment Deficiencies shall be applicable to all
Department Heads.
Auditing shall be addressed within each department as it relates to Quality
Control procedures and employee performance/skill.

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5.8.

REFERENCES
OSHA CFR 1910.119

Occupational Safety and Health

Administration regulations.

QC-PSM-MNL-00-0001

PSM Compliance Manual

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