Both OSHA and EPA require PSM/RMP facilities, more specifically covered process(s), have a QA program in their Mechanical Integrity (MI) Program…
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.
Seems pretty straight forward, right? Well, the state of Nevada, which has NOT officially been “delegated enforcement” has a really nice inspection checklist. And in this inspection checklist, it contents the following questions for the EPA inspector to ask of the facility. How would your MI QA program fair against these questions?