Mechanical Integrity Services
The term, “Regulatory Compliance,” represents a broad field of activities. It may apply to regulations from OSHA, EPA, FDA, DHHS, or other federal agencies, as well as individual state agencies that provide state and local regulatory control over industrial and work-place environments for employees and beyond-the-fence environmental safety. This section of our services is not intended to encompass the full scope of regulatory compliance, but as our offerings cover more than just a single point in the regulatory spectrum, we have chosen to use the broader term. Also, due to regulatory overlap for similar requirements, services that may apply to an OSHA regulation may also apply to similar EPA regulations. Nuances that exist between the two regulations represent interpretational opportunities for those who have studied and applied these regulations to real world situations. Certain OSHA and EPA regulations have had a dramatic impact on the manner in which owner/user organizations conduct their business with respect to safe operation, particularly regarding equipment that contains, processes, transfers or stores highly hazardous chemicals. The two regulations are OSHA 29 CFR 1910.119, “Process Safety Management of Highly Hazardous Chemicals (PSM),” and EPA 40 CFR 68, “Risk Management Programs (RMP).” Interestingly, these regulations may reference other regulations within the full body of the regulatory codes for which a given activity may require additional written guidance and control. Both of these regulations contain elements that require owner/user organizations that operate processes involving highly hazardous chemicals to perform a number of self-regulating tasks, including but certainly not limited to the establishment of detailed design information specific to process equipment, formation of teams to conduct process hazard reviews, and assurance of the mechanical integrity of the process equipment based on documented design conditions.
Reliability Inspections, LLC (RI) is qualified to assist with many of your regulatory compliance needs. Our service offerings include site reviews for compliance issues, PSM/RMP program audits, Process Safety Information (PSI) / Mechanical Integrity (MI) reviews, facilitation of Process Hazard Analysis (PHA) studies, written programs for PSM, PSI and MI including written procedures, and program implementation including PSI documentation (equipment design basis and P&ID development), equipment identification, risk classification, training and qualification, testing & inspection, deficiency correction management, and quality assurance. We have considerable experience with applicable regulations, recognized and generally accepted good engineering practices (RAGAEP), familiarity with most categories of process equipment, understanding of design conditions and specifications, and significant experience in proven compliance-oriented activities. We have worked with regulatory agencies and organizations that were under citation to bring their facilities into an acceptable state of compliance. We have also worked with regulatory issues specific to the state of California. RI employs a number of auditors and inspectors with API and other certifications who are trained and qualified to write and/or implement compliance programs. We can perform site reviews at owner/user facilities, document reviews on or off site, and can develop compliance strategies based on our findings. Our goal is to meet our customer’s compliance objectives within the scope of regulatory requirements in a cost effective and efficient manner, and to assure to the best of our ability continued safe and reliable operation of our customer’s facilities.
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Quality Assurance / Quality Control
Quality Assurance / Quality Control (QA/QC) is a broad description for various types of reviews, tests and inspections that are performed to evaluate equipment, assemblies, components and/or parts that are in the process of construction, fabrication or repair, or have been recently constructed, fabricated or repaired. The general purpose of QA/QC is to assure compliance to a specification. It assumes that equipment and component construction, fabrication and repair are the result of an engineering design that includes detailed specifications. These specifications may be based on an applicable code or may be the result of a unique design produced by a project engineer, or both. In order for QA/QC to be effective, detailed specifications must be documented as the basis for comparison. QA/QC is generally a process. The process begins with the documentation of the detailed specifications and may involve a review of the design to assure that it meets the requirements of its intended purpose. The QA/QC process continues through vendor qualification, material qualification, technical qualification of applicable resources, qualification and verification of methods and practices, intermediate testing, inspection and reviews, and final testing, inspection and reviews, which normally occur at the facility (shop) where the work is being produced. QA/QC practices are guided by a number of codes and standards including publications from the American Society of Mechanical Engineers (ASME), the American Petroleum Institute (API), the American Society for Testing and Materials (ASTM) and the American Welding Society (AWS) but guidance is not limited to publications produced by these organizations. It is the responsibility of an owner/user to determine what code or standard best fits their application, and to provide the detailed specifications that are the comparison basis. The applicable codes generally employ a number of testing and inspection techniques that include but are not limited to visual testing & inspection (VT) including pressure and leak testing, ultrasonic testing (UT), magnetic particle testing (MT) and dye penetrant testing (PT). Quality Assurance in particular is an element of the Process Safety Management rule (PSM) as an integral part of the requirement for Mechanical Integrity (paragraph (j)). From a PSM perspective, the QA that is required by paragraph (j) relies heavily on Process Safety Information (paragraph (d)) which generally specifies requirements for a design basis.
Reliability Inspections, LLC (RI) is qualified to perform QA/QC reviews and inspections for most applications. We have considerable experience with applicable codes & standards, are familiar with most categories of equipment and components, understand the requirement for design basis and detailed specifications and have significant experience in the proven QA/QC process. We can provide QA/QC assistance and services that will meet your needs including design review; vendor, material and resource qualification; pre-service testing & inspection and required NDT. We are also qualified to evaluate and interpret testing results to applicable design and construction codes. RI employs a number of PSM/QA Specialists, API Inspectors, NDT Level II’s and III’s, and AWS Certified Welding Inspectors (CWI) who are trained and qualified to write and/or implement QA/QC programs including full shop reviews. We can perform QA/QC reviews at the owner/user’s facility, vendor facilities, at new construction sites where equipment installation is ongoing, or at fabrication shops where equipment is being constructed or repaired. We can provide QA/QC services for most designs and constructions in a cost effective and efficient manner for customers who have equipment for which QA/QC of is essential for continued safe and reliable operation or may be required by corporate or jurisdictional standards.