Already, in less than 24 hours from when I posted the OSHRC decision on the BP Refinery, I have received over a dozen e-mails asking me “do I have to have U-1 forms for my pressure vessels?”. There are not many PSM/RMP facilities that have not been dinged with one of these findings over the past 20 years. So my response to each one is YES, you MUST have THE DATA on your pressure vessels in order to properly manage these CRITICAL safety items. The OSHRC took issue with the fact that the CSHO actually found ALL THE U-1 form DATA for the pressure vessel in question within 30 minutes! As the OSHRC stated, the U-1 form is NOT listed in the PSI data requirements, BUT here is why the DATA from the U-1 form is ABSOLUTELY CRITICAL and REQUIRED for a properly functioning process safety management system…
So let’s be honest here, YES, the OSHRC vacated the OSHA citation; but in hindsight, they had to. The U-1 form is a piece of paper! It is the data the form provides us that is ABSOLUTELY CRITICAL. In the case of this refinery, they had ALL THE DATA because they had the following:
- the drawings of the pressure vessel,
- the bill of material on the drawings,
- the design code book, and
- the vessel’s nameplate
So to all my clients that I have written up in the past 12 years for not having U-1 forms… I apologize and can assure you it will NOT happen again. Instead I will take the time to peel the onion back a few more layers and instead issue findings on issues with RV design basis, MI Fit-For-Service issues, etc.
In a way, this OSHRC did us all a favor… we can no longer be lazy auditors. We will have to schedule 1-2 days longer for each audit and closely examine our samples for deficiencies other than just not having the U-1 form. No longer can we just pick the low hanging fruit and move along. So what will I be doing from now on?
The U-1 Form
As was so elegantly stated in the OSHRC decision…
The American Society of Mechanical Engineers (ASME) developed a form, known as a U-1 form, which pressure vessel manufacturers use to provide information to their customers. After it has designed and constructed a pressure vessel, the manufacturer issues a copy of the U-1 form to the purchaser. The U-1 form contains important information relating to the safe use of the pressure vessel.
Officially, ASME VIII, UG-120 Data Reports states:
(3) The Manufacturer shall:
(a) furnish a copy of the Manufacturer’s Data Report to the user and, upon request, to the Inspector:
(b) submit a copy of the Manufacturer’s Data Report to the appropriate enforcement authority in the jurisdiction in which the vessel is to be installed, where required by law;
(c) keep a copy of the Manufacturer’s Data Report on file in a safe repository for at least 3 years.
In lieu of (c) above, the vessel may be registered and the Data Report filed with the National Board of Boiler and Pressure Vessel Inspectors, 1055 Crupper Avenue, Columbus, Ohio 43229. Where acceptable to the appropriate enforcement authority in the jurisdiction in which the vessel is to be installed, the vessel may be registered and the Data Report filed with the National Board of Boiler and Pressure Vessel Inspectors in lieu of (b) above.
(4) A Manufacturer’s Certificate of Compliance on Form U-3 shall be completed and signed by the Manufacturer for each pressure vessel marked with the Code UM Symbol. This Certificate shall be maintained by the Manufacturer for 5 years and a copy made available upon request, or the vessel may be registered and the Data Report filed with the National Board of Boiler and Pressure Vessel Inspectors, 1055 Crupper Avenue, Columbus, OH 43229.
Where acceptable to the appropriate enforcement authority in the jurisdiction in which the vessel is to be installed, the vessel may be registered and the Data Report filed with the National Board of Boiler and Pressure Vessel Inspectors. Identical vessels up to 1 day’s production may be recorded on a single Certificate of Compliance.
It has always been said the U-1 form is the “birth certificate” for the pressure vessel. It states when it was built, how it was built, what it was built for, who built it, etc. Of course, ASME also requires that much of the critical data regarding the vessel be displayed on the vessel nameplate (UG-119). But anyone who has come across a vessel with a missing nameplate knows that this can be a major headache. Having the U-1 form on file is the EASY and quick way to get the data when the nameplate is missing. Sometimes we can pay around $75 for a new U-1 form from The National Board of Boiler and Pressure Vessel Inspectors (NBBI), BUT THIS IS NOT a for sure way of getting our data. As stated above, the code does NOT require the manufacturer to file the U-1 form with the NBBI and they are ONLY required to maintain the U-1 form for the vessels they built for 3-5 years.
So with a missing nameplate and no U-1 form on file or no U-1 form available from the NBBI, what is one to do? We ABSOLUTELY MUST have the data for this pressure vessel. But with no nameplate and no U-1 form available we are left with the EXPENSIVE alternative of doing a “fit-for-service” inspection on our vessel. This is an INTENSIVE inspection involving both Non-Destructive Examination (NDE) and Non-Destructive Testing (NDT). A CERTIFIED inspector (usually an API certification) will ultimately create a pseudo-U-1 form data sheet for you so that you can then further evaluate the PV and its relief system to ensure that everything is acceptable for its current service. These “fit-for-service” inspections can be COSTLY just from the price for the inspection; throw in the downtime needed for the vessel inspection and costs can become very burdensome. Not to mention when the report comes back less than favorable and drastic changes are necessary (e.g. rerating the vessel, shortening the life of the vessel, etc.).
I can say this about U-1 data, a facility that does not have the U-1 form data (either on the form or on the nameplate) will have a very difficult time convincing even the novice auditor/inspector that their relief system design basis is valid and their Mechanical Integrity Inspection data is valid.
So rather than writing a finding for a missing U-1 form, check to see if the facility has the necessary data for their RV Design Basis and their baseline MI inspection data. If the facility does not have the U-1 data (either on the form or on the nameplate) we should move directly to:
1910.119(d)(3)(i)(D) Relief system design and design basis
and
1910.119(j)(1)(i) Pressure vessels and storage tanks; coupled with
1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
Think about it…
- If we do not know the MAWP (long with the MAWT) how will-will know what the RV design basis should be?
- If we do not know the date the vessel was built how will an inspector determine erosion/corrosion loss
- If we do not know the nominal thickness of the vessel how will an inspector know how much thickness has been lost over the life of the vessel
These are just a few of the basic items that REQUIRE us to have the U-1 data available. So MAYBE not having the actual U-1 form on file is not a PSM violation… but rest assured NOT having the data on file within the facility is a MAJOR MISS in any process safety management system.
Your thoughts??????