Our facility is facing challenges with meeting strict regulatory testing requirements for safety devices, making it difficult to adhere to the prescribed time frames. With over 7,500 devices to test, manpower availability is proving to be a hindrance. I am seeking advice from the group on whether anyone has implemented a Reliability-Centered Maintenance/ Risk-Based Inspection program for safety device testing at their facility and what outcomes were achieved. Regards, Mike.
Hello Mike, In numerous countries, lawmakers are shifting away from rigid regulations, like the ones you mentioned. Instead, they are focusing on logical and practical approaches to achieve equal or superior risk reduction. Ultimately, it comes down to balancing compliance costs with investment in building a strong case. It would be valuable to assess the financial impact on your business. Can you provide us with some cost estimates?
In the past, I conducted Reliability Centered Maintenance (RCM) analysis on medical equipment, focusing on specific environmental and operational criteria. The results often differed from the recommended maintenance guidelines. However, after demonstrating to the FDA that the proposed tasks effectively addressed critical issues, we were able to obtain approval to adjust our maintenance program in certain areas. I also have recent experience in the bio-tech industry, which presented similar challenges. In this case, we decided not to make changes to procedures due to the high cost involved. Regulatory bodies, especially in industries like pharmaceuticals, are typically resistant to changes that come with significant costs. In my experience, compliance often requires a financial investment. If you want to comply, be prepared to invest. - Ken Culverson
Our website has recently implemented a Pressure Safety Device program that was overlooked during the plant start-up process. Many areas have specific testing requirements for such devices, so it would be wise to create a worksheet outlining these minimum testing requirements. Organizing the testing schedules for the safety devices may reveal that they are staggered, making it easier to plan for testing. In the case of pressure safety devices, we have opted to replace the unit and send it to a certified shop for testing. In our region, certification by a reputable shop is mandatory. Once the units are back at our facility, they are stored in our Spares inventory. This streamlined process has saved us time and effort in the long run.
In my experience, it is not uncommon to find maintenance or testing frequencies in code or regulatory documents phrased as "recommendations" rather than "requirements." This allows for some flexibility for users to utilize technical analyses like RCM to deviate from the suggested schedule. If needed, you can also explore the option of requesting an exception or exemption from the regulatory body. In the realm of fire protection, a notable RCM study was carried out by the Department of Defense back in 1999 focusing on inspection, testing, and maintenance tasks for fire protection systems in facilities. The findings of this study led to the creation of a Unified Facilities Criteria (UFC) document, now serving as the standard in DOD facilities and taking precedence over NFPA 25 and 72. The frequency of tasks outlined in the RCM-based UFC is generally lower compared to NFPA guidelines. Rumor has it that the upcoming release of NFPA 25 is expected to align more closely with RCM principles, adopting a more performance-based and less prescriptive approach. Are there any further insights on this topic? - Shelley
Thank you to all for your valuable comments and suggestions. Allow me to provide some clarity about our state-of-the-art facility situated offshore Nigeria. This facility is a newly constructed FPSO (Floating Production Storage Offloading) designed for efficient oil production. Upon deployment, the anticipated production rates include 250,000 barrels per day, storage capacity of 2.1 million barrels, gas reinjection of 450 million standard cubic feet per day, and seawater injection of 450,000 barrels per day. The staff at the facility is expected to consist of around 100 individuals, with approximately 36 dedicated to maintenance tasks. The challenge we face lies in the maintenance staff count, as the current levels are inadequate to manage the testing of over 8,000 safety devices on a scheduled basis. To address this issue, we are considering transitioning to a Reliability-Centered Maintenance (RCM) approach for the maintenance and testing of these safety devices. In terms of Pressure Safety Valves (PSVs), our plan is to conduct random inspections and testing every 5 years, as suggested by Wally. Our primary focus is on ensuring the reliability and functionality of Fire & Gas devices, gas detectors, thermal/heat devices, fire fighting equipment, among others, due to the extensive list of safety-related devices at the facility. We are exploring the possibility of seeking an exception to current regulations, but to do so effectively, we need to provide examples where regulatory bodies have allowed deviations and flexibility. Once again, I appreciate the insightful comments and feedback. Regards, Mike.
Hey Mike, we also faced similar issues some time ago, and RCM proved to be a game-changer for us. With the help of a Reliability-Centered Maintenance program, we could prioritize devices based on criticality, which effectively reduced the testing workload. This also allowed us to better manage our resources by directing our efforts towards devices that posed the most risk if they failed. Moreover, this approach helped streamline our maintenance planning and consequently improved our compliance with testing requirements. I suggest you invest in a good RCM software and you'll indeed see significant improvements.
Hi Mike, we faced a similar situation at our facility a few years ago. We did implement a Reliability-Centered Maintenance program which helped prioritize safety device testing based on criticality and risk. By identifying crucial devices that had a greater potential of causing significant operational hiccups, we could strategically allocate manpower and resources. The outcome was pretty successful, we had fewer equipment failures, reduced downtime, and could meet regulatory requirements in time. Just be diligent about tailoring it to your specific operation and needs, every facility is different. Good luck.
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Answer: 1. What are the common challenges faced by facilities in meeting regulatory testing requirements for safety devices? - Facilities often struggle with strict regulatory testing requirements for safety devices, making it difficult to adhere to prescribed time frames due to the high volume of devices that need to be tested and limited manpower availability.
Answer: - Yes, some facilities have successfully implemented RCM or Risk-Based Inspection programs for safety device testing to optimize maintenance strategies and prioritize inspections based on risk levels.
Answer: - By implementing an RCM or Risk-Based Inspection program, facilities can improve maintenance efficiency, prioritize testing based on risk levels, reduce downtime, and ensure compliance with regulatory requirements for safety devices.
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