Over the last 15+ years we have seen great improvements regarding piping installation(s) at PSM/RMP covered processes. Since 1992 (PSM implementation) these “covered processes” were required to adopt a RAGAGEP for all aspects of their covered process. ASME has had their B31 series in place for decades and they are the most widely recognized piping RAGAGEPs around. Although the improvements we have seen have been in the field practices where they really matter, we are still seeing lack of a “management system” to ensure all aspects of B31.3 and B31.5 (the two I work most with) are being fully implemented. For example, during a PSM/RMP inspection/audit we should be able to provide the following documentation to OSHA/EPA or an auditor regarding our piping installations:
B31.5 requires the following documentation for the pipe installations:
539 RECORDS
539.1 Definition
Records are the reduction to writing or film image of performances, evaluations, or data required by the Code.
539.2 Responsibility It is the responsibility of the piping designer, manufacturer, fabricator, and erector as applicable to prepare the
records required by this Code.
539.3 Extent and Retention of Records
The following records shall be maintained for 3 yr:
(a) procedure specification, procedure qualification, and performance qualification records
(b) results of weld examinations other than visual
(c) records of the testing of each piping system, which shall include the following information:
(1) date
(2) identification of piping system tested
(3) testing medium
(4) test pressure
(5) signature of examiner and inspector
B31.3 requires the following documentation for the pipe installations:
345.2.7 Test Records. Records shall be made of each piping system during the testing, including
(a) date of test
(b) identification of piping system tested
(c) test fluid
(d) test pressure
(e) certification of results by examiner
These records need not be retained after completion of the test if a certification by the Inspector that the piping has satisfactorily passed pressure testing as required by this Code is retained.
346 RECORDS
346.2 Responsibility
It is the responsibility of the piping designer, the manufacturer, the fabricator, and the erector, as applicable, to ASME B31.3-2016 prepare the records required by this Code and by the engineering design.
346.3 Retention of Records
Unless otherwise specified by the engineering design, the following records shall be retained for at least 5 years after the record is generated for the project:
(a) examination procedures
(b) examination personnel qualifications
(c) examination reports
One document I always teach clients to ask for is the Welding Procedure Specifications (WPS) which should contain all the documentation of the welding and include their pressure testing and leak testing procedures. BUT the records above will most likely be a separate set of documents and in fact could be hundreds of pages of records (depending on the size of your process and how the contractor did their testing) that will have to be managed properly.
