Not a trick question; however, I bet it made you stop and think for a second. There are many stories/scenarios involving LOPC events where a pressure gauge was not maintained or not read properly. This year we got involved in an LOPC event and testing done on the critical pressure gauge showed it was way off in its reading. Of course, the gauge was over 20 years old, had never been calibrated/inspected/tested, and had recently been moved to a new location and service. Unfortunately, the gauge was removed from a non-chemical service to a PSM/RMP-covered process and was not even compatible with the HHC/EHS; but chemical compatibility did not seem to factor in the failure of the gauge, as the internals and seals did not fail. But the gauge was “way off” in calibration. And as you can imagine, our causal analysis has opened Pandora’s compliance box as OSHA (and maybe EPA) are leaning on issuing citation(s) referencing the gauge manufacturer’s recommendations as one RAGAGEP and ASME B40.100, ASME Pressure gauges and gauge attachments as another applicable RAGAGEP that covers “Reuse of Pressure Gauges”. Here is what the manufacturer says about the maintenance of their gauge, as well as what ASME B40.100 says about reusing gauges in different services and locations.
(emphasis by me)