Those of you who practice in the Process Safety arena are well aware of OSHA’s and EPA’s requirements to have “written procedures to maintain the on-going integrity of process equipment.” (1910.119(j)(2).
However, OSHA and EPA also have a section in their Mechanical Integrity elements titled “Quality Assurance.”
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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. |
These three (3) bullet items read almost like ASME B31.3 and 31.5 piping standards and ASME BPVC, Section V, Article 9, the most widely used piping RAGAGEPs in covered processes.
NOTE: The IFC also requires ASME B31 to be used for ALL HAZARDOUS MATERIALS piping, regardless of PSM/RMP coverage. SAFTENG members can read about that in my other articles on “Primary Containment” systems.
But this article specifically discusses the “Written Procedure” requirement for Piping/Weld Examinations as p[part of our Quality Assurance (QA) efforts in the field erection of piping.
(emphasis by me)
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ASME BPVC, Section V, Article 9 T-921 WRITTEN PROCEDURE REQUIREMENTS T-921.1 Requirements. Visual examinations shall be performed in accordance with a written procedure, which shall, as a minimum, contain the requirements listed in Table T-921. The written procedure shall establish a single value, or range of values, for each requirement. T-921.2 Procedure Qualification. When procedure qualification is specified by the referencing Code Section, a change of a requirement in Table T-921 identified as an essential variable shall require requalification of the written procedure by demonstration. A change of a requirement identified as a nonessential variable does not require requalification of the written procedure. All changes of essential or nonessential variables from those specified within the written procedure shall require revision of, or an addendum to, the written procedure. T-921.3 Demonstration. The procedure shall contain or reference a report of what was used to demonstrate that the examination procedure was adequate. In general, a fine line 1/ 32 in. (0.8 mm) or less in width, an artificial imperfection or a simulated condition, located on the surface or a similar surface to that to be examined, may be considered as a method for procedure demonstration. The condition or artificial imperfection should be in the least discernable location on the area surface to be examined to validate the procedure. |
And, of course, if the code is going to require a WRITTEN PROCEDURE to perform these visual examinations of welds/piping installations, it will also have requirements for those persons who will be executing these procedures.
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T-922 PERSONNEL REQUIREMENTS The user of this Article shall be responsible for assigning qualified personnel to perform visual examinations to the requirements of this Article. At the option of the organization, he may maintain one certification for each product, or several separate signed records based on the area or type of work, or both combined. Where impractical to use specialized visual examination personnel, T-923 PHYSICAL REQUIREMENTS Personnel shall have an annual vision test to assure natural or corrected near distance acuity such that they are capable of reading standard J-1 letters on standard Jaeger test type charts for near vision. Equivalent near vision tests are acceptable. |