Creating an Effective Asset Integrity Program

Lauren Moyer a and Matthew Hedlundb

a
Principal Chemical Engineer Plant Protection, Tennessee Operations, Eastman Chemical Company, P. O. Box 1972, Kingsport, TN,
37662; lmoyer@eastman.com (for correspondence)
b
Senior Chemical Engineer Chemicals Development Division, Eastman Chemical Company, P. O. Box 511, Kingsport, TN, 37662
Published online 00 Month 2018 in Wiley Online Library (wileyonlinelibrary.com). DOI 10.1002/prs.12008

Establishing an effective asset integrity management (AIM) intent, the undesirable financial and societal consequences are
program begins with the creation of a leadership team at the often immediately apparent even if a process safety event does
appropriate level of management. The team membership not occur. Documented mechanical integrity-related incidents
should encompass all areas of responsibility for asset integrity. in industry have had tremendous costs in lives, community
Management at the corporate level cannot effectively drive health, environmental impact, and dollars.
execution of the details. Oversight at a low level in the organi- Despite its importance to a company’s sustainability, man-
zation can result in inconsistencies in implementation across aging asset integrity has a number of challenges. Responsibili-
the enterprise or insufficient resources to fully implement the ties for execution of the asset integrity program are often
AIM program. spread throughout the organization and may be segregated by
The AIM program should drive overall risk management equipment type. Section 1.2 of Guidelines for Asset Integrity
for all assets. Regulatory covered processes may have higher Management [2] states that “AIM is a product of many activi-
safety risks, but non-covered assets may still pose significant ties, usually performed by many people….” A silo approach in
business risk that requires elevated coverage. these activities could easily become disorganized and
The AIM program should be established as a full life cycle disjointed. Furthermore, ownership of the asset integrity pro-
program, from design to decommissioning. Clearly defining gram is often weighted toward the reliability/inspection and
and documenting standards, roles, and responsibilities for process safety groups. This often results in a focus on regula-
each phase of the life cycle are essential to an effective AIM tory compliance instead of overall process sustainability.
program. Each role needs to be filled with subject-matter Because of this, the scope of the program beyond regulatory
experts who are actively engaged with the leadership team. compliance may not be well defined. Significant safety and
A successful AIM program can improve existing risk man- business risk could still exist in “non-covered” assets and
agement and reliability efforts through appropriate manage- should be addressed by the asset integrity program. Similarly,
ment direction, thoughtful application of the program to all the focus of the program may be on inspection and testing
assets, and clear documentation of the expectations for the full requirements instead of looking at the full life cycle of the
life cycle of the equipment. © 2018 American Institute of Chemical equipment. Each of these issues points to an overall need for a
Engineers Process Saf Prog 2018 more centered ownership for the AIM program with a focus
Keywords: mechanical integrity; safety management; on all phases of the equipment life cycle.
maintenance
MANAGEMENT LEADERSHIP

INTRODUCTION Roles and Responsibilities—The Who and The What

Mechanical integrity or asset integrity has been recognized Management leadership is a critical element in establishing
as a critical element in process safety for many years. In many a process safety culture and successfully implementing any of
countries (e.g., the United States, the UK, and the European the aspects of RBPS. Guidelines for Asset Integrity
Union), having a formal asset integrity management (AIM) pro- Management [2] lists the following primary responsibilities for
gram is a legal requirement for processing certain types and leadership in AIM:
quantities of chemicals. The Center for Chemical Process
Safety recognizes the overall value of a well-defined and exe- 1. Establishing direction, scope, and culture of the AIM
cuted AIM program in its Risk-Based Process Safety (RBPS) program at the corporate level
approach to process safety management [1]. However, in addi- 2. Ensuring that knowledgeable, trained people are
tion to life safety, asset integrity is also strongly connected to performing appropriate activities with effective tools and
the business and environmental sustainability of the chemical methods
process. If the equipment cannot reliably perform its design 3. Instilling the expectation that the business plan will be
fulfilled only within the safe operating limits of the
equipment as dictated by its condition.
4. Ensuring that AIM program activities are being executed
Prepared for Presentation at American Institute of Chemical Engi-
neers 2018 Spring Meeting and 14th Global Congress on Process Safety
as planned, results are being captured and analyzed, and
Orlando, Florida, April 22–25, 2018. AIChE shall not be responsible for corrective actions are being completed.
statements or opinions contained in papers or printed in its 5. Ensuring that appropriate controls are implemented and
publications. maintained within the facility’s hazard management
© 2018 American Institute of Chemical Engineers system for all related AIM activities

Process Safety Progress Month 2018 1

 6. Providing the necessary resources to accomplish all of
the above activities.
Management at the highest level of an organization must set
the expectations for the process safety program and be commit-
ted to its execution for the program to be successful. However,
directives from the corporate level often resemble the
performance-based standards that the directive was intended to
fulfill. These typically state that a program should be in place
and should serve to prevent an unintended negative conse-
quence, but frequently details of implementation are not well
defined. The larger and more diverse the organization is, the
more likely it is that corporate policies could take this form. On
the other end of the spectrum, implementation of an asset
integrity program by first-line management or by siloed
resources can lead to inconsistency in implementation across
the organization and an inability to direct all the resources nec-
essary to implement the program. Leadership and organization
at the site or regional level are needed to effectively execute
the responsibilities listed above. An AIM management
leadership team comprised mid-level management for a site or
group of sites can provide the right balance to drive company
process safety culture, make risk decisions from a holistic view-
point, and provide resources to implement the AIM program.
Having the right breadth of leadership commitment is equally
important as the right level of leadership to the success of the
AIM program. Asset integrity is unique in process safety disci-
plines in that several diverse areas of expertise and responsibility Figure 1. Resources required for maintaining equipment
are required to achieve the goals of reliable performance and reliability.
prevention of loss of containment events. As illustrated in
Figure 1, operations, maintenance, reliability and inspection
groups, engineering, project management, and process safety intent of several elements of RBPS, such as Process Safety
personnel are all responsible for different aspects of an asset’s Culture, Compliance with Standards, Operating Procedures,
performance through its life cycle and should all have some level Conduct of Operations, Measures and Metrics, Auditing, Man-
of ownership in the AIM program. Communication and coopera- agement Review, and Continuous Improvement.
tion between the site and regional leadership of each of these
groups are necessary to the success of the AIM program.
The management leadership team should provide ownership
and leadership to the AIM efforts for the entire equipment life AIM Leadership Team Benefits
cycle. It should be empowered to fulfill several key functions: There are several key benefits that can be realized from this
1. Recommend AIM policy and practice for the area of approach to AIM. This team of operations, maintenance, engi-
responsibility. This includes determining the scope of the neering, safety, and reliability leaders has an interest in overall
program and the appropriate codes and standards to be risk management and process sustainability and not merely
utilized, and documenting all procedures, practices, roles regulatory compliance. They know the full value of keeping
and responsibilities. processes running and chemicals contained and can manage
2. Determine and monitor appropriate measures. This could the AIM program with these goals in mind.
include determining how best to capture the data rele- Having representation from each of the key groups involved
vant to the AIM program and monitoring for progress or facilitates communication between these groups on asset integ-
areas that need more attention and resources. rity and equipment life cycle issues that could impact the
3. Review and process AIM-related audit findings. The sustainability of the facilities. Also, there is a greater awareness
leadership team should be connected to the regular Process of the roles of each group in the asset integrity process, and that
Safety Management (PSM) audit processes for their facilities can lead to potential improvements in effectiveness and
and work to address findings related to asset integrity. efficiency. This group should be in a position of leadership to
4. Monitor overall health of AIM processes. Ensuring health set priorities and direct resources to execute the AIM proce-
of the program includes both a look back at past data dures and policies, optimize implementation priorities, and
but also a look forward to new codes and standards and address any changes or enhancements needed.
continual improvement. Monitoring the health of the AIM program allows the
5. Establish appropriate operational discipline related to leadership team to be proactive instead of reactive in
mechanical integrity (MI) processes. The leadership team addressing any issues associated with how the program is
should be able to establish a culture of asset integrity in being executed at the site/region. For example, routine “health
their facilities. checks” of the programs for various equipment disciplines can
6. Report to site/corporate management periodically. This be conducted with the leadership team and the stewards of
establishes a connection between corporate process that discipline. Three key questions should be asked during
safety culture and goals and the AIM implementation pol- these reviews:
icy of the site/region.
1. What is going well in the program?
These roles correspond closely to the overall management 2. What are the gaps for this program?
responsibilities laid out in the Guidelines for Asset Integrity 3. What changes might be coming for this program (new
Management recommendations listed above and meet the standards/code, new technologies, etc.)?

2 Month 2018 Published on behalf of the AIChE DOI 10.1002/prs Process Safety Progress
 Finally, an engaged AIM leadership team can provide leader- safety, business, and other potential risks can ensure that the right
ship in process safety culture for the organization. This middle level of coverage is applied to all the assets in the facility.
management group is visible to both operations personnel and
LAYING THE PROGRAM FOUNDATION
corporate management and can engage with both groups on the
importance of process safety and how asset integrity impacts pro- Documenting the scope and requirements of the AIM pro-
cess safety. Providing clear communications in both directions is gram from the management leadership team to the mainte-
an important role for this group. With a clear leadership model in nance and inspection personnel involved is important for the
place, further improvements in the AIM program can be realized. consistent execution of the program. Procedures should be
written that clearly document the scope of the program,
ALL-ENCOMPASSING PROGRAM expectations for execution, and roles and responsibilities.
Regulations, such as OSHA 1910.119 [3], mandate which pro- One important step is in realizing that all equipment is not
cesses are subject to process safety regulation based namely on created the same and cannot be handled together in one single
toxicity, flammability, and quantities. While adhering to this AIM process. Design codes and standards, inspection technolo-
ensures regulatory compliance, a good AIM program should gies and frequencies, failure modes, and repair considerations
have a more holistic approach to risk management. are all very different between pumps, vessels, piping, tanks,
and instrumentation. Separate AIM subprocesses should be
documented for each equipment type, with appropriate
Example 1 Heat transfer media systems (e.g., Therminol, subject-matter experts for that equipment type serving as a
Dowtherm, Syltherm) pose inherent safety risks that steward for that procedure. The stewards are ideally based in
may require treating these systems as if they were regu- engineering or reliability functions with detailed knowledge of
latory covered processes, although they do not meet the the equipment type and the applicable codes, standards, and
coverage requirements in some jurisdictions. best practices. These stewards are responsible for maintaining
the procedures and processes and providing routine “health
Example 2 Processes that contain toxic and/or flamma- checks” to the leadership team on their portion of the program.
Figure 2 shows a possible arrangement for equipment specific
ble material inventories below the regulatorily-defined
procedures. This could vary based on resources, asset types,
minimum quantity may also require treating as if they and organization of resources for a given site or group of sites.
were covered. Depending on how process and organi- When developing the procedures for the AIM program, a
zational (PHA) boundaries are established, storage and tiered approach can provide the right level of information to
process areas may be segregated. This could leave the the right resources at all parts of the program. Figure 3 illus-
process area having insufficient quantities of hazardous trates this hierarchy of procedures. A general procedure, main-
materials to be a covered process, yet still poses a tained by the management leadership team, should define the
potential process safety risk. overall scope and expectations of the program, responsibilities
of the management team, and standard measures and tools to
be used. The equipment type stewards discussed above would
Although safety plays a vital role in risk management, non- be responsible for the Equipment-Specific Procedures. These
covered assets may pose a significant business risk that require procedures should cover the scope of program coverage for
elevated coverage. that equipment type, asset integrity requirements and responsi-
bilities along the life cycle of that equipment, and general
information on inspection methods and frequencies. These
Example 3 Refining of a non-regulatorily-covered chemi- procedures will reference other established documents such as
cal is considered non-covered; however, if it is crucial to design codes, regulations, internal standards, inspection proce-
the business, it should be maintained at a much higher dures, work practices, and training documents.
level. Although there may not be a significant safety risk,
FULL LIFE CYCLE PROGRAM
loss of production can be a major concern that impacts The AIM program should be established as a full life cycle
how process equipment is inspected and maintained. program, from design (cradle) to decommissioning (grave).
Defined roles and responsibilities throughout the life cycle are
Having diverse leadership, particularly operations and mainte- a key aspect. Management, subject-matter experts, project
nance leaders, involved in the AIM program with visibility to teams, and operations all help in the creation and design of an
effective AIM program and need to actively engage with the
leadership team on a regular basis.
Early decisions made in the design stage have a significant
impact to managing future assets. Materials of construction, vessel
ratings and design specifications, equipment spares, reducing
chemical inventories, facility siting considerations, and other deci-
sions greatly affect the management and cost of the AIM program.

1. Higher metallurgies can greatly reduce corrosion rates

and increase equipment life.
2. Higher pressure/temperature ratings can reduce the need
for additional relief and/or control systems.
3. Spare pumps can eliminate the need to wait until process
turnarounds to repair seal leaks.

For the design process to be successful, the correct subject-

matter experts need to be aligned with the AIM program goals.
Figure 2. Suggested divisions of equipment types for AIM The capital process may be aimed at reducing costs whenever
programs and procedures. possible, thinking in the short-term without consideration of
increased operating costs and reduced reliability and

Process Safety Progress Published on behalf of the AIChE DOI 10.1002/prs Month 2018 3
Figure 3. Proposed procedure structure for an AIM program.

operability. A holistic approach guarantees a balance between tanks”. Previously, pressure vessels and storage tanks were
short-term and long-term benefits. Subject-matter experts for managed together under the same mechanical integrity proce-
each process/equipment type should be appointed as stew- dures and programs. However, because of the legal require-
ards to define relevant mechanical integrity standards and pro- ments of pressure vessel code in some states, pressure vessel
cedures and give guidance during design to ensure those construction, inspection, and repair requirements tended to
standards are being met. These standards should be main- dominate the program.
tained in a central location with all other standards to maintain By including key engineering, inspection, and safety exper-
consistency across projects and operating areas. tise on the Site AIM Leadership Team, it became apparent that
Properly commissioning new equipment guarantees every- low pressure storage tanks should be managed separately
thing is consistent with the intended design and is in good from pressure vessels to improve the effectiveness of the
working order before chemicals are introduced. Fabrication is inspection and repair practices. A group of storage tank
not guaranteed to be accurate, and important design con- subject-matter experts then developed an asset integrity proce-
straints can get lost in installation. Meeting a construction dure that addressed asset integrity issues from design and con-
schedule is important; however, if critical conditions are not struction through inspection and repairs for both storage tanks
met, the leadership team should give guidance on delaying and their secondary containment structures.
startup or creating a plan to reasonably correct the issue. Because a very large site or a group of sites can include
The operating phase of the life cycle is the core of a good thousands of low pressure storage tanks, a risk-based
AIM program and covers everything from startup, inspections, approach was employed to manage such a large program. Fac-
corrosion monitoring, managing change, and responding to tors such as age, material of construction, tank contents, oper-
deficiencies. This phase requires the highest level of coordina- ating conditions, and potential business impact were used to
tion and communication between manufacturing, mainte- prioritize inspection schedules instead of simply regulatory
nance, process safety, and reliability organizations. coverage.
Manufacturing staff need to be aware of how to properly and Fully implementing this program of inspections is a multi-
effectively manage their areas to increase facility up-time and year effort, but the site has already seen benefits in planned
reduce risk. Although manufacturing holds the key to provid- inspections and repairs and prevention of chemical releases
ing the necessary information, they need direction from equip- and business interruptions. This renewed focus on low pres-
ment subject matter experts and the leadership team on how sure storage tanks as a stand-alone discipline has also resulted
to properly and effectively manage asset integrity for the in improvements in inspection tools and techniques at the site
facility. and an optimization of inspection practices based on require-
Decommissioning may not seem like it belongs in an AIM ments in different safety and environmental regulations for dif-
program, but it is especially important when there is a possibil- ferent types of tanks.
ity of reusing equipment. It also becomes critical when assets
are abandoned in place and processing areas become overly
Optimizing Inspection Responsibilities
congested and difficult to operate. The vessel inspector may
seem like the gatekeeper, but it is operations that need to pro- Another example of improvement lies in optimization of
vide guidance on how to decommission their equipment as they roles and responsibilities. By having a leadership team led by
are the ones who will live with those decisions going forward. operations and maintenance and having that team connected
By having the AIM program involved at all stages through- with the right subject matter experts, the types and frequencies
out the life cycle of the process, costs can be optimized with of inspections can be optimized. For example, many pieces of
reliability and operability. It is this optimization that is key as equipment, such as piping and pumps, can be effectively visu-
minimizing costs or maximizing reliability that can increase risk ally inspected for potential defects by operations personnel on
either to the process safety or to the financial performance, their daily rounds through the area. Operations personnel
respectively. should be trained on what to look for and how to report defi-
ciencies, but training on these first-tier inspections can be
accomplished by simple online job training modules. Having
OVERALL SUCCESS STORIES operations personnel serve as the first level of inspection can
save considerably on inspection labor costs. The daily pres-
Low Pressure Storage Tanks ence of operations personnel in the area can help get many
The creation of an asset integrity leadership team and deficiencies identified and addressed more quickly than occa-
restructuring asset integrity processes based on the principles sional scheduled outside inspections.
above has resulted in measurable improvements in managing
the reliability of the equipment at a large chemical process site. CONCLUSION
One most notable improvement is in the handling of low pres- Asset integrity programs ensure that the process continues
sure storage tanks. Per OSHA 1910.119, mechanical integrity to operate as designed and with same reliability assumed at
programs should be applied to “Pressure vessels and storage the beginning of the life of the process. They are required by

4 Month 2018 Published on behalf of the AIChE DOI 10.1002/prs Process Safety Progress
regulation for some operating processes, but a good practice procedures can be used by engineering, construction, opera-
to ensure continued reliable performance for all assets. A tions, maintenance, and reliability personnel to ensure that the
recent edition of the Process Safety Beacon [4], highlighting equipment is appropriately designed and constructed and con-
mechanical integrity concerns, stated that “You don’t get what tinues to be reliable for its entire life. This reliability is a critical
you expect, you get what you inspect.” Although inspections component in preventing loss of containment events and the
are a crucial component to equipment reliability, a well- resulting safety and environment impacts.
managed AIM program should be more than just inspection
and testing programs to provide maximum benefits. LITERATURE CITED
A cross-functional management leadership team for a site 1. CCPS, Risk Based Process Safety, Center for Chemical Pro-
or region or group of sites can ensure that the AIM program is cess Safety, American Institute of Chemical Engineers,
applied to the right assets with the right level of detail for the New York, NY (2007).
entire life cycle of the equipment. Involvement from the oper- 2. CCPS, Guidelines for Asset Integrity Management, Center
ations and maintenance organizations can drive a clear focus for Chemical Process Safety, American Institute of Chemical
on overall sustainability and risk management. This team can Engineers, New York, NY (2017).
ensure that the program scope and resources are optimized 3. 29CFR1910.119, Process Safety Management of Highly
for the facility and that the program is continually improving. Hazardous Chemicals (1992)
Defining appropriate subject-matter experts to develop pro- 4. Process Safety Beacon, Chemical Engineering Progress,
cesses and procedures with a life cycle view of the equipment American Institute of Chemical Engineers, New York, NY
is key in executing the AIM program. These processes and (2015)

Process Safety Progress Published on behalf of the AIChE DOI 10.1002/prs Month 2018 5