PSM's most common struggle: Implementing mechanical integrity

Most companies have found that of the 14 OSHA PSM elements, Mechanical Integrity (MI) presents the greatest implementation challenge. Although maintenance departments have successfully installed, repaired, and replaced plant equipment for decades, many of these same maintenance departments have struggled with OSHA's PSM requirements. One major challenge is prioritizing resources. Opportunities to improve will always exist; however, it is often difficult to effectively allocate money and manpower. Another challenge is simply getting organized. The MI program should be supported by appropriate, useful procedures; but given the multifaceted and ever‐changing nature of maintenance, what procedures should be written? How detailed should the procedures be? With nearly 3 years of PSM enforcement complete, an analysis of OSHA's MI citations helps to provide insight to these challenges. This paper presents ideas for implementing MI in a manner that meets OSHA's expectations while contributing to safe, effective maintenance in PSM‐covered processes. In particular, the paper presents ideas for developing MI programs that effectively prioritize company resources, with appropriate inspection/test/preventive maintenance and quality assurance (QA) activities. This paper also presents ideas for developing a list of mechanical integrity procedures to address OSHA's requirements as well as the type of information to include in those procedures.