There is one small little sentence in 1910.119 (as well as Part 68) that is causing all kinds of heartburn. I like to call this requirement the “General Duty Clause” of process safety. To fully understand what this requirement entails we first have to understand what is meant by a standard being a “performance oriented” standard, which PSM (and RMP) is. A performance oriented standard is “open ended”; by this I mean that OSHA does not prescribe the exact way to comply. Take 1910.23 for example, OSHA says that a guardrail must have a top rail at 42″, mid rail at 21″ and a toe board that is 4″ high and less than 1/4″ from the surface. The standard also has strength specifications, materials of construction specifications, etc. That is pretty “prescriptive” and does not leave much to the imagination as to how a guardrail MUST be constructed and installed! The PSM standard is MUCH MORE open as the standard is meant to be a management framework that can be used in all types of processes handling highly hazardous chemicals (HHC) and extremely hazardous substances (EHS). Now there are certain parts of the PSM standard that are prescriptive, such as Process Safety Information (PSI); but for the most part, the 14 elements are set up as a management system framework and the employer is expected to “adopt” (i.e. implement) consensus standards/codes for the design, installation, operations, and maintenance of their process(s) equipment. And this is where 1910.119(d)(3)(ii) comes into play…
1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
So what is OSHA/EPA looking for from us to demonstrate our process(s) meets a RAGAGEP? How do I have to have to “document my equipment complies with RAGAGEPs”? Well that all depends on the RAGAGEPs that are used by the process. In this article I will use as my example an Ammonia Refrigeration process. To frame this article up, I first need to classify my process equipment as each class of equipment could have a different applicable RAGAGEP. For the sake of time I will only be discussing one class of equipment in this article, but you should be able to see how we document that each class of equipment complies with our chosen RAGAGEP(s). The class of equipment that I am going to use is one that OSHA has recently been on a rampage on… PIPING!
Before proceeding I would like to point out that ALL of the RARAGEPs we use are intended to be listed in our PSI. This is required by
1910.119(d)(3)(i)(F) Design codes and standards employed.
It is here that we must list all of the RAGAGEPs we have used to Design, Construct/Install, Operate, and Maintain our process equipment. In some cases this may be a very long list, but it is fair game for OSHA/EPA to ask for this listing per each class/category of equipment.
The first step in documenting that our process piping complies with an RAGAGEP is the design of the process piping (e.g. the runs, size, materials of construction, slants, etc.). Most in the Ammonia Refrigeration industry turn to ASHARE, IIAR, or ASME for these specifications.
- ASHRAE 15 – Safety Standard for Refrigeration Systems, Chapter 9. DESIGN AND CONSTRUCTION OF EQUIPMENT AND SYSTEMS
- ANSI/IIAR 2-2008 – Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems, Section 10 Piping
- ASME B31.5 – 2010 Refrigeration Piping and Heat Transfer Components
All of these RAGAGEPs establish a materials of construction and schedule for the piping. They even include specifications for labeling, piping supports, etc. Trust me when I say that “labeling, pipe supports, etc.” are ALL part of demonstrating your process complies with your chosen RAGAGEP! You see when we “adopt” our RAGAGEP of choice, then that is what OSHA/EPA will audit/inspect to. And when they find that we have not met the adopted RAGAGEP they can then cite that our process does not comply with RAGAGEP (e.g. 1910.119(d)(3)(ii). So when they find piping not labeled, or labeled but not to the RAGAGEP labeling specification, this is an EASY citation for them. The other easy find is missing or broken pipe supports. I will also mention here that pipe schedules and supports are designed based on the expected load of the HHC and insulation. Any ice build-up of any substantial size may be viewed by OSHA/EPA as placing too much stress on the pipe design. Of course, any ice formation on any insulation is a sign that there has been a vapor barrier breach and “corrosion under insulation” (CUI) becomes a large question that the facility will have to successfully argue they have identified this potential issue and they have it under control via their pipe inspection program (more on this later). So that is the first hoop we jump through to show our piping meets RAGAGEP, and most can pass this level; however, OSHA/EPA are now peeling the proverbial inspection onion back a few more layers these days.
The next layer they expect to see is the methods of installation of the pipe. This would entail having documentation that each weld was completed by a certified welder. Both ASHARE 15 and IIAR 2 are “cliff notes” from ASME B31.5 when it comes to piping. What I mean by this is that both of these industry specific codes in regards to piping orginated from ASME B31.5. Regardless of which codes says what, ALL three codes require installation documentation that the pipe was installed per the “code” and lets not forget the PSSR is meant to document we have VERIFIED the pipe was the correct pipe and installed correctly. So what kind of documentation should we have to demonstrate this? Here are a couple of the basics:
1) Pressure test results,
2) Leak test results, and
3) welding certifications that show each weld was completed by a certified/coded welder.
Now for those who may not believe me, there is a difference between a “leak test” and a “pressure test” and BOTH are required and BOTH require a WRITTEN PROCEDURE to conduct! For example, for those that have listed ASME/ANSI B31.5 as your piping RAGAGEP, are you meeting the documentation requirements for installation of your pipe? Here are two of the requirements from ASME B31.5 that we often find missing in records:
527.5 Records: After completing a welded joint, the welder or welding operator shall identify it as his or her work by applying his or her assigned symbol for permanent record in a manner specified by his or her employer.
539.3 Extent and Retention of Records: The following records shall be maintained for three years: (a) procedure specification, procedure qualification, and performance qualification records; (b) results of weld examinations other than visual; and(c) records of the testing of each piping system, which shall include the following information: 1) date; 2) identification of piping system tested; 3) testing medium; 4) test pressure; and 5) signature of examiner and inspector.
Now let’s be clear here… these requirements are directly from the RAGAGEP that the business chose on its own. OSHA/EPA did not force the business to use this RAGAGEP; it was chosen. These are NOT new requirements, as they have been in B31.5 for “several” editions and are often practiced in chemical processing and other high risk industries. Let’s look at these two RAGAGEP requirements more closely.
B31.5, Section 527.5 requires that when a welder completes a weld, that weld can then be traced back to that welder. The most common practice is for the welder to stamp his/her weld, but there are other acceptable methods to do this. Either way, the owner of the process should end up with (and I should state as PART OF THE PSSR and no later) the following documentation:
(a) the piping procedure specification, piping procedure qualification, and piping performance qualification records;
(b) results of weld examinations other than visual; and
(c) records of the testing of each piping system, which shall include the following information:
1) date;
2) identification of piping system tested;
3) testing medium;
4) test pressure; and
5) signature of examiner and inspector.
(d) PASS/FAIL of “leak test”
All of this testing should be done “circuit” by “circuit” so it is ensured that ALL newly installed or welded on pipe is qualified for use in the PSM/RMP process. Of course, it is acceptable to say all your piping is one big circuit, but that will only create massive headaches when it comes time to do the NDT/NDE on it later on.
One question that you may get from an inspector is “how do you know that carbon steel pipe, schedule 80 actually was used where it was supposed to be used” vs. someone making an error and installing schedule 40 pipe or some other materials of construction. What they are digging for is some kind of evidence that the facility has a “quality assurance program” (e.g. 1910.119(j)(6)) for new construction or large scale repairs. Don’t kid yourself into believing that the wrong materials of construction or wrong schedule of pipe don’t make their way into places you never imagined they would be found! In fact some of the major accidents have come from piping failures that involved incorrect design and/or materials of construction! So ask yourself, how do I know the pipe that was spec’ed out for my process is the actual pipe that got installed? What evidence do I have to prove to OSHA/EPA that I know the process was built as designed? Simply showing a completed PSSR is NOT going to cut it in a real PSM/RMP inspection!
The next phase of this exercise is the Mechanical Integrity aspect. Once our pipe is installed and operational, we have to have some type of NDT/NDE of the piping and to do this we must adopt a RAGAGEP to direct our inspection type and frequency. ASHARE-15 and IIAR-2 are NOT pipe inspection codes, so although they were useful to use in the design and construction phases, there is nothing in them that will guide us in establishing an inspection/testing program that meets a RAGAGEP.
Although many in the refrigeration industry cringe at the sound of these three little letters… API, it is API 570 that best suits almost any MI inspection and testing program for a PSM/RMP covered process. But again, although the adoption of API 570 is the right thing to do, there are many requirements that must be met and documented in order to put the icing on your case that your process meets a RAGAGEP.
The very first step is to “circuitize” your piping. Then we will determine which API Class each circuit of piping will be assigned. API breaks down the process piping into four classes, with each class having different inspection requirements based on risks. Remember when I said that saying all your piping in the process is one big circuit and that this would cause problems in the long run… well we have arrived at that point! There is actually MUCH ADVANTAGE to spending the time and breaking down the process piping into circuits and then classifying each circuit. So again, when OSHA/EPA ask us to demonstrate that our process meets a RAGAGEP, we will need to show that we have a mechanical integrity program for our piping and that this program meets API 570 (or some other RAGAGEP).
The ultimate test we can give ourselves is the following:
Point to a section of pipe on a P&ID or in the field and we should be able to show the pipe was spec’ed properly to meet our chosen RAGAGEP, installed properly per our chosen RAGAGEP, inspected and tested properly during installation, but certainly BEFORE the introduction of the HHC/EHS, and that the pipe is being inspected properly and at the proper frequencies based on our chosen RAGAGEP(s).
Can your process piping pass this level of scrutiny to demonstrate it meets an RAGAGEP?
Stay tuned, if you liked this article I am thinking of writing one for Pressure Vessels and Relief Valves. Would you find this helpful? Let me know in the comments below.