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?
QA/QC (Quality Assurance / Quality Control)
Quality Assurance is the management oversight function of the portion of the Mechanical Integrity Program procedure that deals with the proper specification, procurement, receiving, warehousing and installation of process components Quality Control is the technical function of the Mechanical Integrity Program that ensures verification that the process components were installed according to the Quality Assurance Program.
What system is in place to ensure:
a. Are proper materials specified?
b. Are specified materials ordered?
c. Are specified materials received?
d. Are specified materials issued for installation?
e. Were specified materials correctly installed? (Please NOTE that “a PSSR” is NOT a correct answer here, as NOT all changes require a PSSR!)
CLICK HERECLICK HERE for the full MI Checklist from Nevada Division of Environmental ProtectionA