September 16, 1996

Mr. Sylvester W. Fretwell
Director of Safety
Lever Brothers Company
818 Sylvan Avenue
Englewood Cliffs, NJ 07632

Dear Mr. Sylvester:

This is in response to your March 28 letter requesting interpretation of the process safety management (PSM) of highly hazardous chemicals standard, 29 CFR 1910. Please accept our apology for the delay in responding. Specifically, you requested clarification on the documentation of inspections and tests required under the mechanical integrity provisions of paragraph 1910.119(j). Your PSM scenario and questions and our response follow.

Scenario: Lever Brothers Company has four components in the inspection and testing portions of our mechanical integrity program for PSM. They are: (1) routine inspection; (2) external visual inspection; (3) internal visual inspection; and (4) condition and/or functional testing. The mechanical integrity documentation requirements for internal visual inspections and for functional testing are no problem to fulfill and keep for the individual items of equipment. However, routine and external visual inspections are conducted at a higher frequency and cover large groups of equipment in a short time. Documenting findings for every aspect of the inspection for each individual item of equipment results in mountains of paper which cannot be realistically managed.

Question: Would it be allowable, under the PSM mechanical integrity inspection and testing documentation requirements, to:

(1) document routine and external visual inspections by noting only conditions needing attention, rather than by marking every field in extensive checklist?

(2) document inspections by process unit, rather than by individual items of equipment, with only deficiencies noted by individual items of equipment?

(3) maintain inspection records in computer databases rather than on paper?

As an extension of (3) above, if a work order for an inspection, with checklist, is issued by a computerized work order system, is it adequate documentation to indicate that the work order was completed; or is it necessary to keep a paper copy or a computerized copy of the completed checklist?

Also, for how long must inspection records be kept? Is only the most recent inspection record, supplemented by a history of prior inspections and findings sufficient?

Reply: As noted at the top of the middle column on page 6389 of the preamble to the enclosed PSM Final Rule, the goal of the mechanical integrity requirements under paragraph 1910.119 "is to ensure that highly hazardous chemicals covered by the standard are contained within the process and not released in an uncontrolled manner." As such, an employer must maintain the ongoing mechanical integrity of at least the process equipment listed under paragraph 1910.119(j)(1).

Under paragraph 1910.119(j)(4)(iv), an employer must document each of the inspections and tests required under paragraph 1910.119(j)(4)(i) to identify, in addition to other information, "the results of the inspection or test." Documentation of both negative and positive results were intended for reference in determining the on-going mechanical integrity of the process. For example, both positive and negative results are used to determine the frequency of inspections and tests based on operating experience vis-a-vis manufacturers' recommendations and good engineering practices of the industry. Therefore, as long as the inspection procedures make clear that the absence of a finding in the inspection report indicates a positive finding, this would meet the intent of the standard.

The provisions of the PSM Standard, including the mechanical integrity requirements, are performance-oriented. As such, an employer has the option of formatting paragraph 1910.119(j)(4)(iv) required documentation of process equipment inspections and tests required under paragraph 1910.119(j)(4)(i) by process unit. Computers may be used to maintain paragraph 1910.119(j)(4)(iv) required documentation as long as the information is readily retrievable and accessible as reference information.

In order to demonstrate compliance with paragraph 1910.119(j), and to meet the purpose of ongoing mechanical integrity, the documentation required under paragraph 1910.119(j)(4)(iv) must be kept for the lifetime of the process.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact Mr. Ronald Davies of my staff, telephone # (202) 219-8031, extension 110.

Sincerely,



John B. Miles, Jr., Director
Directorate of Compliance Programs