As we end 2023, we will have exceeded 30+ years of OSHA’s Process Safety Management (PSM) standard. And yet, still today, we can walk out into a random covered process, place our hand on a process component, and the facility will struggle to provide us a “cut-sheet” for the component (i.e., what), when it was installed, and who installed it. With this comes pressure testing and leak testing for the installation. For example, walk out into the process, place your hand on a run of piping, and the facility should be able to demonstrate the following:
- Materials of Construction for the piping
- The Schedule of the Piping (i.e. wall thickness and pressure rating)
- Who welded the joints or Torqued the flanges (includes the WPS or torquing procedures)
- If the pipe is coated, what is the coating, what procedure was used to apply it properly
- If the pipe is insulated, the insulation specs and the procedure used to apply it properly
- Pipe labeling meets ASME A13.1
- Pipe installation meets ASME B31 series (WPS, installation inspections, pressure and leak testing)
- Piping is in an MI program, and if it is insulated, the MI program includes CUI risks
- Piping is supported properly
- Valves in piping have spec sheets showing proper pressures, compatibility with the HHC/EHS
- Hydrostatic relief devices (if used) design basis
- If the pipe is over 5-10 years old, we should have an inspection record based on its Hazard Class (API 570)
- Work Order history of work done on the piping, valves, hydrostats, etc.
I think you get the point. We should be this detailed at this point in the maturity of our PSM/RMP management system. If the facility is not yet there, a detailed plan on how we get to this point and how long it will take is needed.