Don't Let Them Shut You Down: Part 3

Don't Let Them Shut You Down: Part 3

Also to consider is OSHA code 29 CFR Part 1910.119. The section listed below specifically states that equipment will be maintained and the history of maintenance will be documented. It goes one-step further by identifying safe operations as part of the requirement.

1910.119(d)(3)(iii)

• For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.

1910.119(j)(3)

• Training for process maintenance activities. The employer shall 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 the employee can perform the job tasks in a safe manner.

1910.119(j)(4)iv

• The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify 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.

1910.119(j)(5)

• Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.

A significant factor in maintenance is the potential for change in a piece of capital equipment. In the Texas City BP case study, there were several pieces of instrumentation that had been changed without proper documentation. This affected several business processes downstream, specifically, startup procedures. Due to historical events like Three Mile Island and Chernobyl, the Nuclear Regulatory Commission (NRC) has created excellent guidelines for configuration & change management.

10 CFR 50.65

• (a)(1) Each holder of an operating license for a nuclear power plant under this part and each holder of a combined license under part 52 of this chapter after the Commission makes the finding under § 52.103(g) of this chapter, shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph (b) of this section, are capable of fulfilling their intended functions. …When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken….


• (4) Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. …


• (b) The scope of the monitoring program specified in paragraph (a)(1) of this section shall include safety related and non-safety related structures, systems, and components, as follows:


• Safety-related structures, systems and components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in Sec. 50.34(a)(1), Sec. 50.67(b)(2), or Sec. 100.11 of this chapter, as applicable.


• Non-safety related structures, systems, or components:


• That are relied upon to mitigate accidents or transients or are used in plant emergency operating procedures (EOPs); or


• Whose failure could prevent safety-related structures, systems, and components from fulfilling their safety-related function; or


• Whose failure could cause a reactor scram or actuation of a safety-related system.

Some may suggest that in addressing CFR’s, all that is necessary is to draft a procedure or policy. That may be true until the production process has a failure that affects product quality (e.g. Pharmaceuticals) or people are injured or killed (e.g. Chemical Processing, Pharmaceuticals, Aviation, Manufacturing). This exposes the company to higher risk and has the resultant negative publicity. In regulated industries, federal marshals can walk in with a warrant and walk out with executives in handcuffs.

The most basic parts of a reliability program will address compliance requirements, mitigate or eliminate failures and reduce the cost to maintain assets that fall under various CFR’s. The reason for this is the components of a comprehensive reliability program go deep into the business processes across organizational units as well as the company as a whole. In addition, new regulations or stringent enforcements of existing regulations may not become necessary.

In order to have a successful reliability program there must be the following components:

• Maintenance History Tracking


• Standard Operating Procedures (SOP)


• Materials Specification Requirements


• Materials Stores Management (MRO)


• Management of Change (MOC)


• Maintenance Business Process


• Design for Reliability

These components provide a foundation to build good data on the asset base, thus improving equipment health. The information gathered gives the entire business unit the power to make well-informed decisions. Everything from product quality to throughput capacity can be identified in the context of reliability.

Taking the road to reliability enables the organization to do the right thing for its company and the community in which the company resides. Eliminating failures and exceeding regulatory requirements will reduce government intervention and lead toward a more proactive organization/environment. Less government oversight will reduce operating expenses once thought necessary to achieve compliance.