Received the most interesting phone call today and there is one more business on the plante that thinks I have completely lost my mind. Their question: “If the manufacturer of a piece of equipment has a recommended maintenance plan, and we do not follow their “recommendation”; how can OSHA issue a citation against a “recommendation”?” I know there are others who may be asking the same thing, but to make this brief I will put it like this….
The manufacturer of the equipment is best suited to establish operating and maintenance parameters! They just call them “recommendations” as legally they cannot require the purchaser to do anything once they are in possession of the equipment. It is much like the cars we drive; they come with a recommended maintenance plan and once we own the car we are in no way obligated to have the maintenance performed. Of course there are consequences for these decisions and in the case of the car, the owner will be making their warranty OBSOLETE and in the biggest way this impacts the owner (however there is an argument that others could be impacted by an unsafe car on the road). In the case of the PSM employer, not following the recommended maintenance plan will also cause the warranty to become OBSOLETE; however, for the PSM employer OSHA has a standard 1910.119) that REQUIRES the equipment owner to abide by the maintenance plan. This is called Process Safety and in my opinion this is the most basic element of process safety.
Some manufacturers of equipment used in PSM/RMP covered processes make equipment that comes with NO maintenance plan. For example, this happens with most vessels/tanks. The manufacturer will make the vessel/tank to a specification (e.g. API or ASME) and then it is up to the employer to establish the maintenance plan BASED ON HOW the vessel/tank will be used. This is when we turn to our Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) for direction.
Bottom line, when a manufacturer RECOMMENDS a maintenance plan, it is MORE THAN A RECOMMENDATION in the world of Process Safety. We can do MORE and do it MORE FREQUENT than the manufacturer recommends, but we can NOT treat it as an everyday “recommendation” in the world of process safety. Lack of following the manufacturer’s recommendation is handing OSHA/EPA a Serious Citation on a silver platter.