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Course 736 - Introduction to Process Safety Management

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Mechanical Integrity and Hot Work Permit

PSM mechanical integrity requirements apply to pressure vessels and storage tanks.
PSM mechanical integrity requirements apply to pressure vessels and storage tanks.

Mechanical Integrity

OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly.

PSM mechanical integrity requirements apply to the following equipment:

  • pressure vessels and storage tanks;
  • piping systems (including piping components such as valves);
  • relief and vent systems and devices;
  • emergency shutdown systems;
  • controls (including monitoring devices and sensors, alarms, and interlocks); and
  • pumps.

The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment.

Training

Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employee's job tasks.

The employer must train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that employees can perform their jobs in a safe manner.

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices.
Inspection and testing must be performed on process equipment.

Inspection and Testing

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must be consistent with and conform to applicable manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience.

Each inspection and test on process equipment must be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

The employer must document each inspection and test that has been performed on process equipment. The documentation must include:

  • the date of the inspection
  • name of the person who performed the inspection or test,
  • the serial number or other identifier of the equipment inspected or tested,
  • a description of the inspection or test, and
  • the results of the inspection or test.

Equipment Deficiencies and Quality Assurance

Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation.

In constructing new plants and equipment, the employer must ensure that equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The employer also must ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

A permit must be issued for hot work operations conducted on or near a covered process.
A permit must be issued for hot work operations conducted on or near a covered process.

Hot Work Permit

A permit must be issued for hot work operations conducted on or near a covered process. The permit must:

  • document that the fire prevention and protection requirements in OSHA regulations (1910.252(a)) have been implemented prior to beginning the hot work operations;
  • it must indicate the date(s) authorized for hot work; and
  • identify the object on which hot work is to be performed. The permit must be kept on file until completion of the hot work.

Optional Exercise

Scenario:

Art and Ray were sent to the Tank Farm to replace bearings on an isopropanol pump located on the alcohol pad. They found the bearings “frozen" in place. When Art told his supervisor they would have to pull the pump, he said, “Let’s see if we can’t pull those bearings in place; we’ve got too much downtime in that area already." First they tried to loosen the bearings with a bearing heater, a powerful electric heat gun, without success. Ray then called a welder who heated the casing with her torch until the bearings came free. While the welder was there, the supervisor had her weld brackets on an I-beam so he could install a “Warning-Flammable Area" sign.

A piece of slag from the welding rolled into a nearby pile of damp wooden shims. After the mechanics and the welder left the area, the wood began to smolder and then burst into flames. At the same time an operator began to charge ethanol to his unit by remote computer control. The ethanol transfer pump started to leak around its mechanical seal creating a pool of alcohol on the pad. The vapors from the pool traveled towards the fire, which then ignited them.

The fire spread instantly to the pump and grew in intensity as the heat increased the size of the leak. The tank farm operator saw the fire, sounded the alarm and attacked the fire with an extinguisher. She was overcome by vapors and fell unconscious. Quick response by the in-plant emergency response team saved her life and stopped a potentially disastrous fire.

Task:

Discuss the incident and, based on your experience, answer the following questions.

  1. What could have been done to prevent this fire? List the factsheet(s) you used to back up your answer.
  2. Now, think about the hot work program in your plant, are there any changes or improvements that should be made to improve the program? Please list and explain.

Video

Watch this CSB video about the key lessons to prevent flammable vapor explosions caused by welding and cutting.

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. According to the text, PSM mechanical integrity requirements apply to all of the following equipment, EXCEPT:

2. Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employee's job tasks.

3. Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected or tagged with “caution" signs.

4. The employer also must ensure that all of the following are suitable for the process application for which they will be used, EXCEPT:

5. A permit must be issued for hot work operations conducted on or near a covered process. The permit must:


Have a great day!

Important! You will receive an "error" message unless all questions are answered.