Process Safety: Info We Need from Equipment Manufacturers

“If you don’t live up to somebody’s standards, you get hammered.”  — Anthony Rendon

I drive a 2006 Toyota Corolla. When I bought it in 2008, the odometer read 11,499 miles. In 2013, when the odometer crossed the 100,000-mile threshold, I declared my hope to reach 250,000 miles. The car is now closing in on 300,000 miles and I am beginning to entertain hopes of it running to 500,000 miles.

One of the things that contributed to the car’s long life is a 42-page booklet that came with the car: 2006 Scheduled Maintenance Guide. Not only does it include maintenance and inspection items to be completed every 5,000 miles or six months (whichever comes first), it includes an explanation of those maintenance items.

I was recently asked about the information that process operators should request from equipment manufacturers when they purchase equipment for use in a process covered by the Process Safety Management (PSM) standard, 29 CFR 1910.119. I immediately thought of my Scheduled Maintenance Guide.

However, there is more to it than that.

Information Pertaining to the Equipment in the Process

The second element of the 14 elements of the PSM standard is (d) Process Safety Information (PSI). OSHA requires three types of PSI:

1. Information pertaining to the highly hazardous chemicals in the process.
2. Information pertaining to the technology of the process.
3. Information pertaining to the equipment in the process.

When purchasing equipment for use in processes covered by the PSM standard, the process operator should insist that the manufacturer of the equipment provide the “information pertaining to the equipment in the process.”

So, what is that information?

OSHA requires eight kinds of equipment information. Three kinds of equipment information are specific to individual pieces of equipment:

(A) Materials of construction;
(C) Electrical classification;
(F) Design codes and standards employed.

This is information that the process operator should insist on getting from the equipment manufacturer as a condition of purchasing their equipment.

Some of that information, though, is not about specific pieces of equipment. Rather, it is about the assembled system and relates to the process rather than specific pieces of equipment. This includes

(B) Piping and instrument diagrams (P&ID’s);
(D) Relief system design and design basis;
(E) Ventilation system design;
(G) Material and energy balances for processes built after May 26, 1992;
(H) Safety systems (e.g., interlocks, detection or suppression systems).

That said, even some of this information may be relevant for specific pieces of equipment, like the internal relief on a gear pump, the P&IDs for a purchased skid-mounted unit, or the interlocks on a burner management system. The time to get it is at the time of purchase.

Recognized and Generally Accepted Good Engineering Practices

“Recognized and generally accepted good engineering practices” (RAGAGEP) is a phrase that many have heard so often that they can hardly be blamed for thinking that it is ubiquitous in OSHA regulations.

It is not.

RAGAGEP is only used in the PSM standard, and there, it is only used three times. The first time is in the PSI element for equipment:

1910.119(d)(3)(iii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices.

While this responsibility falls to the employer using the equipment and not to the manufacturer of the equipment, it is the equipment manufacturer who will know what practices they used when they manufactured the equipment. Again, this is information that the process operator should insist on getting from the equipment manufacturer as a condition of purchasing the equipment.

RAGAGEP is used two other times in the standard, both in the eighth element of PSM: (j) Mechanical Integrity (MI). Unlike the requirement for equipment information in PSI, the requirements of MI are specific to six types of equipment. For those six types of equipment, however, OSHA requires

1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.

1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.

In other words, equipment manufacturers should say what inspection and testing should be done, how to do it, and how often it should be done. Once again, this is information that the process operator should insist on getting from the equipment manufacturer as a condition of purchasing the equipment.

Manufacturers’ Recommendations

OSHA considers manufacturers’ recommendations as RAGAGEP. The PSM standard mentions manufacturers’ recommendations twice, once in 1910.119(j)(4)(iii) and once in the paragraph on Quality Assurance:

1910.119(j)(6)(ii) Appropriate checks and inspections shall be performed to assure that the equipment is installed properly and consistent with design specifications and the manufacturers’ instructions.

There is another requirement in the section on MI that depends on recommendations from the equipment manufacturer, even though OSHA does not explicitly mention manufacturers’ recommendations:

1910.119(j)(6)(iii) The employer shall assure that the maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.

To that end, the process operator should get a recommendation from the equipment manufacturer regarding maintenance materials, spare parts and equipment, especially in terms of what needs to be kept on hand and what can be kept stocked by the manufacturer.

Information We Need from Equipment Manufacturers

To summarize, there are several types of information process operators need from manufacturers of equipment that will be used in processes covered by PSM:

• Materials of construction
• Electrical classification
• Design codes and standards employed
• Other process safety information, as relevant
• Certification that equipment complies with RAGAGEP
• Instructions for properly installing the equipment
• Inspection and testing to be done on the equipment
• Instructions for performing inspection and testing on the equipment
• Frequency for performing inspection and testing
• Recommendations for spare parts, maintenance materials and equipment

Get It While It’s Hot

This is a lot of information. All of it is essential to complying with the requirements of PSM. Hard experience says that it is much more difficult to get this information years after the equipment has been purchased and installed. Instead, the time to get it is at the time the equipment has been ordered and befo