I first wrote about this API 510 requirement in July 2019, and now OSHA appears to have caught up with this requirement; this year, they issued their first citation related to this requirement. Of course, the citation was associated with a process covered by PSM. Here is the API 510 requirement for newly installed pressure vessels, along with the OSHA citation resulting from failing to perform these “pre-use” inspections.
6.2 Inspection During Installation and Service Changes
6.2.1 Vessel Installations
6.2.1.1 Pressure vessels shall be inspected by an inspector at the time of installation. The purpose of this inspection is to verify the equipment is safe for operation and that no unacceptable damage occurred during transportation to the installation site, and to initiate plant inspection records for the equipment. This inspection also provides an opportunity to collect desired baseline information and to obtain the initial thickness readings at designated CMLs. The installation inspection shall verify:
a) the nameplate information is correct per the manufacturer’s data reports and design requirements;
b) the equipment is installed correctly, supports are adequate and secured, exterior equipment such as ladders and platforms are secured, insulation is properly installed and flanged, and other mechanical connections are properly assembled and the vessel is clean and dry;
c) PRDs satisfy design and installation requirements per the requirements in API PR 576.
Here is OSHA’s citation wording: (emphasis by me)
Text For Citation: 01 Item/Group: 006B Hazard:
29 CFR 1910.119(j)(4)(i): Mechanical integrity. 29 CFR 1910.119(j)(4)(i): Inspections and tests shall be performed on process equipment. On or about November 15, 2023, the employer failed to perform initial inspections and tests related to pressure vessels and pressure vessel pressure-relieving device installation prior to putting the equipment into service. Inspections and testing had not been performed by a qualified and certified API 510 inspector on ASME code pressure vessels, for the following covered process equipment:
a. Storage Tank ST-101A located in the CESS Storage Area,
b. Storage Tank ST-101B located in the CESS Storage Area,
c. Storage Tank ST-102A located in the CESS Storage Area,
d. Storage Tank ST-102B located in the CESS Storage Area,
e. Storage Tank ST-103A located in the CESS Storage Area,
f. Storage Tank ST-103B located in the CESS Storage Area,
g. Waste Tank WT-101 located in the CESS Storage Area,
h. Separator Tank SP-301 located in the CESS Storage Area,
i. Separator Tank SP-302 located in the CESS Storage Area,
j. Separator Tank SP-303 located in the CESS Storage Area, and
k. the 20 Buffer Tanks located in the production building packaging line area which include Buffer Tanks BT-101A through BT-110B.
Pressure vessels that have not received initial inspections are at increased risk for loss of containment and overpressure protection system failure. Employees working on and in the vicinity of equipment containing highly hazardous chemicals are exposed to fire, explosion and contact hazards.
Source: https://www.osha.gov/ords/imis/establishment.violation_detail?id=1710650.015&citation_id=01006B