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POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 1 of 10
TABLE OF CONTENTS
1.
INTRODUCTION................................................................................................ 2
2.
3.
DEFINITIONS ..................................................................................................... 3
4.
5.
RESPONSIBILITIES .......................................................................................... 9
6.
REFERENCES ................................................................................................... 10
Rev.
Issue Date
Amendment Description
0
1
01-Jul-2009
07-Oct-2012
First Release
Periodic review / Approver Change/Formatting changes
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Prepared
By:
KK/MT
KSK
Chkd
By:
RC
MVT
Apprd
By:
RGY
ABM
RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 2 of 10
1. INTRODUCTION
This policy defines the requirements concerning RLOC s commitment to meet
the Occupational Safety and Health Administrations, (OSHA), Process Safety
Management (PSM), regulations.
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2. SCOPE / PURPOSE
The intent of this document is to establish what standards/activities are required
on Process Equipment to reduce/prevent the risk of a potential unsafe situation
through an uncontrolled release of hazardous chemicals. While this document
may be considered generic, more specific details of how this policy is executed
/enforced are found in the Equipment Integrity Manual, RC-PSM-MNL-30-0002.
The requirements set forth in this document are based on OSHA PSM
regulation CFR 1910.119 (j) Mechanical Integrity and Q-Chem Operational
Excellence program, Element 3.8, Incident Prevention, Quality, and Reliability.
This document applies specifically to the following equipment types/systems.
Pressure Vessels
Tanks
Piping Systems
Relief and Vent Systems
Pumps, Compressors, and Drivers
Fired Heaters and Boilers
Heat Exchangers
Fire Protection Equipment/Systems
Controls and Emergency Shutdown Systems
Electrical System Equipment
Critical Buildings and structures
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RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 3 of 10
3.
DEFINITIONS
Maintenance
Inspection
Testing
OE
PSM
MOC
PSSR
PHA
QA
QC
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RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 4 of 10
4.4
4.1
4.2
4.2.1
Design
The Design phase is the first step in an equipments life. During this phase
information from different sources shall be used to ensure equipment can
contain the product being handled and can be operated/maintained reliably.
Equipment design shall be based on Company and Industry Codes and
standards. Where Company and Industry Codes and Standards do not exist
or apply, industry recognized and accepted good engineering practices shall
be utilized.
PSM element, Management of Change, shall be used to coordinate design
changes along with new additions as a means to ensure proper reviews are
conducted with subject matter experts prior to implementation. The MOC
element applies not only to entire engineered equipment such as pumps,
compressors, etc. but also individual components such as the mechanical
seal and bearings with respect to Equipment Integrity.
Design documentation requirements shall follow PSM element Process.
Process Hazards Analysis, shall be conducted as part of the design process
as applicable, to identify the correct level of process control.
4.2.2
Purchasing/Contracting
Purchasing requirements based on the equipment types identified in Section
2 of this document along with items at the component level such as bearings,
chemicals, etc. shall be utilized as part of an overall Material Purchase,
Verification, Storage, and Handling Guideline. The emphasis being on the
front end during material selection to prevent errors as well as establish
material/equipment requirements through documented specifications as
necessary.
Contractor acceptance criteria/performance reviews as defined in PSM
element shall be used to manage contractor performance and ensure
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RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 5 of 10
Fabrication/Construction
Quality Control/Assurance requirements as part of a standard and/or specific
to the job such as part of the Scope of Work shall be used to assure proper
materials of construction are used, personnel are qualified, controlled work
practices (welding, bolting, torque, lubrication, etc), as well as work is
conducted in accordance with the Design requirements.
4.2.4
Receiving
Receiving inspection plays an integral part of the overall Material Verification
and Storage Guideline as mentioned in Section 4.2.2 of this document.
Standard receiving inspection requirements shall be put in place including
Positive Material Identification, Material Certification, Test Certificates, etc. to
assure material received is as per the original order.
Receiving inspection requirements shall include off-site activities and verified
using Quality Assurance plans both formal and informal.
Material not meeting established/defined requirements shall be registered as
a Non-Conformance as per Section 4.3.3 of this document.
4.2.5
4.2.6
Installation/Startup
Installation/Start-up is fundamentally affected by and addressed by the same
points identified in Fabrication/Construction, Section 4.2.3, above.
A Start-up control point review for any new addition or modification shall
utilize PSM elements, MOC, PSSR.
4.2.7
Operation
Safe/continued operation of process equipment requires that the operation
stays within the design limits of equipment as well as the equipment condition
understood.
Correct operation is accomplished specifically through
application of the following PSM elements and practices.
Correct operation includes the application of chemicals, additives, and
gases introduced into the process during the course of operating the unit.
Understanding the equipment condition along with maintaining the equipment
requires the timely execution of inspection and testing activities. Inspection
and testing activity content and frequency shall be based on Company, Code,
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RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 6 of 10
Maintenance
Maintenance activities\practices shall focus on planned events as opposed to
breakdown. As such, work order planning and execution controls shall be
established to ensure the QC/QA requirements are addressed prior to job
execution.
Quality control/assurance documentation/activities, including
documents typically referred to as Standard Maintenance Procedures, shall
be used as applicable to ensure the correct materials are used as well as the
job is executed and documented in accordance with Company and Industry
accepted best practice.
Personnel executing maintenance, inspection, and testing shall be
qualified\trained to conduct these activities.
4.3
4.3.1
Equipment Deficiencies
Equipment deficiencies may be defined as any equipment condition, physical
and/or operating, that is not per design. These deficiencies may include
errors in the original manufacturing, construction, or repair as well identified
as the following for example.
RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
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4.3.2
Equipment History
Recording of equipment history is an important aspect of any integrity
program to identify problems/issues not immediately evident at the time of
repairs/failures as well as serve as reference for future works. Equipment
History shall be recorded to support the following activities.
Inspection activity completion verification
Repetitive Problem identification
Spare Parts needs
4.3.3
Non-Conformance
Material and/or activities not in compliance with established Company
requirements concerning Equipment Integrity shall be defined as NonConforming. A Non-Conformance system shall be used to identify and
address non-conformance issues through the use of action items, specifically
for improper material selection/delivery and quality control compliance.
4.3.4
Training
Personnel involved in Equipment Integrity shall be informed and trained as
necessary to ensure these individuals are qualified to perform the tasks per
the required procedures/practices. Training for Equipment Integrity activities
shall be based on the specific QC/QA documents and follow the requirements
established in the PSM element.
.
4.3.5
Auditing
Auditing is a necessary activity to ensure compliance as well as serve as a
means for review/continuous improvement. Compliance with this Equipment
Integrity Policy shall be accomplished per the following means.
i.
Quality Assurance
Quality Assurance Plans shall be utilized to verify compliance with
Company Quality Control and Industry Codes for the following equipment
types and/or activities.
The need and depth of Quality Assurance Plans for other equipment types as
identified in Section 2 of this document shall be decided on an individual
basis.
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RC-PSM-PCY-30-0008
POLICY
REV. 1
07-OCT-2012
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ii.
Procedure/Practice Review
Each department will be responsible for routinely reviewing their
procedures and processes that support the Equipment Integrity program
to ensure they are functioning properly. The frequency of such review
shall be determined by the respective procedure/process department
owner unless dictated by the PSM Manual, QC-PSM-MNL-00-0001.
Failure Analysis
Breakdown Maintenance by definition is a direct result of equipment failures
and a time to be avoided based on the additional safety and integrity issues
that arise as opposed to planned maintenance. Equipment failures are to be
understood so as to learn from them and prevent their re-occurrence.
Failure\Root Cause determination shall be based primarily on the Why Tree
method of analysis. Additional methodologies may be employed depending
on the circumstances of the event.
4.3.7
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RC-PSM-PCY-30-0008
POLICY
EQUIPMENT INTEGRITY POLICY
REV. 1
07-OCT-2012
Page 9 of 10
5.
RESPONSIBILITIES
Department Head responsibilities shall be based on their involvement in
activities defined in this document. Primary ownership/responsibility of the
general areas mentioned in this document is defined as follows, with other
Departments providing a supporting role. Individual responsibility shall be
defined in the specific QC/QA document that supports this policy.
5.1.
5.2.
Maintenance Superintendent
5.3.
Technical Superintendent
RC-PSM-PCY-30-0008
POLICY
REV. 1
07-OCT-2012
Page 10 of 10
5.4.
Materials Manager
Responsible for Quality Control as it applies to activities conducted by
Material
personnel
as
well
as
Contractors
under
Material
supervision/direction.
Define the skill level required and ensure all employees are properly trained
and have the level of qualification/skill to execute Material Department
activities as per
Purchasing/Contracting section, 4.2.2, of this document.
Receiving section, 4.2.4, of this document (with respect to deliveries onsite)
Storage and Handling section, 4.2.5, of this document.
5.5.
HSE Superintendent
Responsible for Quality Assurance of Fire Protection Equipment/Systems.
5.6.
5.7.
All Superintendents
Responsibility for addressing Equipment Deficiencies shall be applicable to all
Department Heads.
Auditing shall be addressed within each department as it relates to Quality
Control procedures and employee performance/skill.
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5.8.
REFERENCES
OSHA CFR 1910.119
QC-PSM-MNL-00-0001
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