Those of you who practice in the Process Safety arena are well aware of OSHA’s and EPA’s requirements to have “written procedures to maintain the on-going integrity of process equipment.” (1910.119(j)(2).
However, OSHA and EPA also have a section in their Mechanical Integrity elements titled “Quality Assurance.”
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1910.119(j)(6) Quality assurance. 1910.119(j)(6)(i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. 1910.119(j)(6)(ii) Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer’s instructions. 1910.119(j)(6)(iii) The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used. |
These three (3) bullet items read almost like ASME B31.3 and 31.5 piping standards and ASME BPVC, Section V, Article 9, the most widely used piping RAGAGEPs in covered processes.
NOTE: The IFC also requires ASME B31 to be used for ALL HAZARDOUS MATERIALS piping, regardless of PSM/RMP coverage. SAFTENG members can read about that in my other articles on “Primary Containment” systems.
But this article specifically discusses the “Written Procedure” requirement for Piping/Weld Examinations as p[part of our Quality Assurance (QA) efforts in the field erection of piping.
(emphasis by me)