Sometimes things happen that are beyond our control as Process Safety Engineers, and in reality, this is where/how we earn our keep. As our RAGAGEP (API 510) says, “Deferrals should be the occasional exception, not a frequent occurrence.” The standard provides a rational, risk-based methodology for managing an inspection that cannot be performed by its due date; however, I have experienced several occasions when the business did not want to document its reasoning for delaying an inspection. This opens the door to real risks and compliance issues with OSHA/EPA. So let’s discuss what needs to be done to “defer an inspection”.
Let’s first look at some of the key statements in API 510, Section 6.7, Deferral of Inspections, Tests, and Examinations… (emphasis by me)