One of the more common misses by a lot of businesses, especially those using pressure vessels (PVs) in their PSM/RMP covered processes, is the “initial inspection” at the time of installation. We have discussed the “change of service” inspection several times; however, this inspection is for NEW PVs being installed. This requirement will certainly apply to those facilities that have adopted API 510 as their PV inspection RAGAGEP, as well as any state or local jurisdiction that has adopted it.
The code is very clear in its language, so why many miss this requirement is beyond me. Kudos to OSHA for starting to issue citations against this requirement:
(emphasis by me)