If you’re involved in process safety you know about mechanical integrity and what is mandated by OSHA’s PSM and EPA’s RMP in regards to MI. But many businesses are just scratching the surface with their mechanical integrity program(s). This article is meant to help those who are looking to take their MI program(s) to the next level. Using other government agency MI requirements as “a guide”, we find some excellent resources that can be adopted by any industry to evaluate and improve their MI program(s). In this article I will be referencing the Pipeline and Hazardous Materials Safety Administration (PHMSA) requirements for how operators of “pipelines” have to evaluate the effectiveness of their MI program as it relates to their pipelines. As I said, this effort can EASILY be transferred to any process that falls under PSM/RMP. Here is what PHMSA requires of the pipeline operators in regards to evaluating the effectiveness of their “Pipeline MI program”…
Before I get into this material, I just want to say upfront that what is being stated in the article is MUCH DIFFERENT than what takes place in a PSM/RMP 3-year audits! It is my professional opinion that a big chunk of MI efforts that are missing in many programs is an overall evaluation of the MI data from all the inspections/test done over a period of time. This is what PHMSA is driving towards with this material and this is MUCH DIFFERENT than what a 3-year audit would normally be looking at.
An integrity management program begins with the initial framework. A facility should continually change the program to reflect operating experience, conclusions drawn from results of the integrity assessments, other maintenance and surveillance data, and evaluation of consequences of a failure on process equipment. A written integrity management program should at least include the following elements:
- methods to measure the program’s effectiveness
- methods to measure whether the program is effective in assessing and evaluating the integrity of process components
An effective performance evaluation process must have the following characteristics:
- A well-defined description of the scope, objectives, and frequency of program evaluations.
- The use of periodic self-assessments, internal or external audits, management reviews, performance metrics analysis, benchmarking against other operators, or other self-critical evaluations to assess program effectiveness.
- Clear performance goals and objectives to measure the effectiveness of key integrity activities.
- Clear assignment of responsibility for implementing required actions.
- Review and follow-up of program evaluation results, findings, and recommendations, etc., by appropriate company managers.
Appendix C to Part 195—Guidance for Implementation of an Integrity Management Program provides more specific guidance on establishing MI performance measures, including the need to select measures based on the understanding and analysis of integrity threats to each pipeline segment. Appendix C also describes three general types of metrics that an integrity management program should have:
- Activity Measures that monitor the surveillance and preventive activities that are in place to control risk. These measures indicate how well an operator is implementing the elements of its integrity management program.
- Deterioration Measures that monitor operational and maintenance trends to indicate if the program is successful or weakening, or if the desired outcome is being achieved or not, despite the risk control activities in place.
- Failure Measures that reflect whether the program is effective in achieving the objective of improving integrity. These are typically lagging indicators that measure the number of releases, the volume spilled, percent recovered, etc.
NOTE: Section 13 “Program Evaluation” of API Standard 1160 – Managing Integrity for Hazardous Liquid Pipelines, also provides additional guidance on the program evaluation process in which these measures are used to improve performance.
A clear and meaningful set of performance metrics is essential to program effectiveness. An effective program for measuring integrity management program effectiveness should have the following characteristics:
- A description of the type of performance measures to be used, along with the data sources, data validation and quality assurance activities, the frequency of data collection, and any normalization factors.
- A means to update the performance measures (if needed) to assure they are providing useful information about the effectiveness of integrity management program activities.
- The use of performance metrics data to check and calibrate the operator’s risk analysis tools to assure these best represent the performance of the operator’s specific assets.
Performance metrics that should be included, such as the number of piping circuits assessed, number of anomalies found requiring repair or mitigation, etc., are a small subset of the overall suite of metrics used by a facility to evaluate its program. A much larger set of operator-specific metrics to be used internally is needed to effectively evaluate an integrity management program performance. Metrics should be developed for each of the following:
- Overall program effectiveness indicated by the number of releases, number of injuries or fatalities, volume released, etc.
- Specific threats that include both leading and lagging indicators for the important integrity threats on an operator’s systems.
These include:
- Activity Measures that monitor the surveillance and preventive activities that are in place to control risk.
- Deterioration Measures that monitor operational and maintenance trends to indicate if the program is successful or weakening despite the risk control activities in place. (Alsoidentified as Operational Measures in ASME B31.8S.)
- Failure Measures that reflect whether the program is effective in achieving the objective of improving integrity. (Also identified as Direct Integrity Measures in ASME B31.8S)
- Metrics that measure and provide insights into how well an operator’s processes associated with the various integrity management program elements are performing. Examples of such processes would include integrity assessment, risk analysis, the identification of preventive and mitigative measures, etc.