Mechanical integrity is the program that ensures critical process equipment remains safe and reliable throughout its service life. Under 29 CFR 1910.119(j), employers must establish written procedures for maintaining equipment, train maintenance employees, conduct inspections and tests per recognized standards, correct deficiencies, and ensure that new equipment is suitable for its intended service. Equipment failures are a leading cause of catastrophic process incidents, making this one of the most operationally significant PSM elements. Ecesis PSM software provides mechanical integrity and preventive maintenance tracking to keep your equipment program organized and audit-ready.
What OSHA Requires
Under 29 CFR 1910.119(j), employers must apply mechanical integrity requirements to the following equipment categories:
- Pressure vessels and storage tanks
- Piping systems (including components such as valves)
- Relief and vent systems and devices
- Emergency shutdown systems
- Controls (monitoring devices, sensors, alarms, interlocks)
- Pumps
The standard requires employers to:
- Establish and implement written procedures to maintain the ongoing integrity of process equipment
- Train each employee involved in maintaining the ongoing integrity of process equipment
- Perform inspections and tests on process equipment following recognized and generally accepted good engineering practices (RAGAGEP) such as API, ASME, and NFPA standards and manufacturer recommendations
- Document each inspection and test, including date, name of person performing, serial number or identification, description of inspection or test, and results
- Correct deficiencies in equipment that are outside acceptable limits before further use, or implement interim protective measures
- Ensure that equipment is designed, maintained, inspected, tested, and operating according to applicable standards and that new equipment is suitable for the process application
Step-by-Step Implementation
Build Your Critical Equipment Inventory
Create a comprehensive inventory of all process equipment falling under the six categories OSHA specifies. For each piece of equipment, document:
- Unique equipment identification number
- Equipment type and category
- Location within the process
- Design specifications (pressure, temperature, materials of construction)
- Applicable design code or standard
- Manufacturer information and original installation date
- Current operating conditions
This inventory becomes the master list for scheduling inspections, tracking deficiencies, and demonstrating program completeness during audits.
Develop Written Maintenance Procedures
Write procedures for maintaining each category of covered equipment. Procedures should reference the applicable industry standards (RAGAGEP) and should cover:
- Inspection methods and acceptance criteria for each equipment type
- Testing procedures and frequencies based on industry standards and manufacturer recommendations
- Preventive maintenance tasks and schedules
- Criteria for determining when equipment is outside acceptable limits
- Procedures for correcting deficiencies including documentation requirements
- Quality assurance for maintenance materials (gaskets, bolting, replacement parts)
Establish Inspection and Testing Schedules
Based on industry standards and manufacturer recommendations, establish inspection frequencies for each piece of equipment. Common standards include:
- Pressure vessels: API 510 (minimum every 10 years external, every 5 years internal, with risk-based adjustments)
- Storage tanks: API 653 (external inspections every 5 years, internal based on corrosion rates)
- Piping: API 570 (risk-based inspection intervals)
- Relief devices: API 576 (typically every 5 years, process-dependent)
- Instrumentation: ISA and manufacturer-recommended calibration intervals
Document the basis for each inspection frequency and track schedules through your compliance calendar.
Train Maintenance Personnel
Each employee involved in maintaining covered process equipment must be trained on:
- The specific processes and hazards they will encounter
- Applicable maintenance and inspection procedures
- Safe work practices for the maintenance activities they perform
- Proper use of inspection and testing equipment
Document training with employee names, dates, topics covered, and comprehension verification. Maintain certifications for specialized activities such as welding, NDE testing, and instrument calibration.
Implement Deficiency Management
When inspections or tests identify equipment outside acceptable limits:
- Remove the equipment from service or implement documented interim protective measures immediately
- Evaluate the deficiency to determine root cause and extent of condition
- Repair, replace, or re-rate the equipment as appropriate
- Verify repairs through appropriate testing before returning equipment to service
- Document the deficiency, corrective action, and verification of repair
- Evaluate whether similar equipment in the facility may have the same deficiency
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software provides comprehensive mechanical integrity management:
- Preventive maintenance: Schedule recurring inspections and tests for all covered equipment with automatic work order generation and overdue notifications
- Inspection tracking: Document inspection results with the mobile app including photos, measurements, and pass/fail determinations
- Deficiency management: Track deficiencies to corrective action completion with assigned owners and due dates
- Training records: Maintain maintenance personnel training and certification records with automatic refresher scheduling
Frequently Asked Questions
What are recognized and generally accepted good engineering practices (RAGAGEP)?
RAGAGEP refers to published industry standards and codes from organizations like API, ASME, NFPA, and ISA that establish minimum requirements for equipment design, fabrication, installation, inspection, testing, and maintenance. OSHA expects mechanical integrity programs to follow these standards.
Do we need to inspect every piece of piping?
Risk-based inspection approaches (such as API 580/581) allow you to focus inspection resources on the highest-risk piping circuits based on factors like corrosion rates, operating conditions, consequence of failure, and inspection history. Not every pipe segment needs the same inspection frequency.
How should relief device testing be documented?
Document the device identification, set pressure, test date, test results (actual opening pressure and reseat pressure), name of person performing the test, and whether the device passed or failed. If a device fails testing, document the corrective action and any evaluation of whether the process was at risk during the period since the last test.
What about equipment designed to older codes?
Equipment designed and fabricated under older code editions does not need to be retroactively upgraded to current codes. However, inspections and continued fitness-for-service evaluations should use current standards and methodologies such as API 579 (Fitness for Service).
How do we handle equipment with no manufacturer recommendations?
When manufacturer recommendations are not available, use applicable industry standards (RAGAGEP), engineering judgment, and operating experience to establish inspection and maintenance procedures. Document the basis for your approach.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
