SEMS Element #8- Mechanical Integrity

I have found many companies out there, both large and small, struggle with this area. Most of the time it is because they both overthink it and make it complicated or don’t realize that they have the information to comply with this requirement in front of them. This is an area where software and audits (9001, 14001, 18001, Q2, 31000, etc) can really benefit your program. Software can help you track your evidence, ensure competency, define inspection methods and even notify you when things are overdue or simply out of operating limits. Continuous auditing of this area of operations can provide you valuable leading indicators before a dreaded lagging indicator occurs. The results of these audits will help you develop the needed quality assurance, procedures, processes and management of change process that will need to be intertwined into this area of operations. I will explain 30 CFR 250.1916 below:

§ 250.1916 What criteria for mechanical integrity must my SEMS program meet?

You must develop and implement written procedures that provide instructions to ensure the mechanical integrity and safe operation of equipment through inspection, testing, and quality assurance. Your mechanical integrity program must encompass all equipment and systems used to prevent or mitigate uncontrolled releases of hydrocarbons, toxic substances, or other materials that may cause environmental or safety consequences.

Stop and think of the systems on an offshore facility and you will have a short list of what is not covered in the above requirement. Unless you can prove (Yes, hazard analysis) that a component doesn’t have anything to do with the items mentioned in that short paragraph, consider it to be part of those systems.

These procedures must address the following:

(a)     The design, procurement, fabrication, installation, calibration, and maintenance of your equipment and systems in accordance with the manufacturer’s design and material specifications.

I highly recommend third party auditors to facilitate the continuous audits while including your personnel involved in these operations in the audit team. This will provide the most bang for your buck and give your personnel the increased competency required in these areas. Human behavior factors (ASTM F1166) are to be a part of these processes. This includes when a modification/ management of change is required.

(b)     The frequency of inspections and tests must be in accordance with BSEE regulations and meet the manufacturer’s recommendations. Inspections and tests can be performed more frequently if determined to be necessary by prior operating experience.

A few companies simply state they conduct their maintenance programs as per the manufacturers’ specifications. This is adequate when you have a well-developed information management program related to manufacturer recommendation updates, documentation control, manufacturer related training, near miss tracking, and equipment failure tracking to include root cause analysis. All of these things may determine that more frequent maintenance is required.

(c)      This documentation must identify the date of the inspection or test; include the name and position, and the signature of the person who performed the inspection or test; include the serial number or other identifier of the equipment on which the inspection or test was performed; include a description of the inspection or test performed; and the results of the inspection test.

(d)     The assurance that maintenance materials, spare parts, and equipment are suitable for the applications for which they will be used.

This is business continuity. Most companies struggle in this area. Again, proper policies and auditing are required.

A failure in this area of operations is unacceptable for the entire industry.