Blog: What's on the minds of Asset Optimization Consultants

From breaking ground with the development of the base resource document for API 580 to writing corporate risk policies for major refiners and petrochemical manufacturers, AOC's consultants have provided thought leadership in many areas of asset integrity, asset performance management, and risk based inspection. Our blog provides a forum for our consultants to share industry insights, lessons learned, tips and tricks, and anything else pertaining to what we do. Check in frequently to see what is on our minds.

  Why is Management Of Change (MOC) so poorly executed

by Michael Hurley, 3/17/2026

Tags: Asset Performance Management Consequence Corrosion CUI Damage Mechanisms Data Analysis Data Management Data Validation HSE Human Factors Mechanical Integrity Process Safety Management Regulation Risk Risk Analysis Risk Management System Implementation Work Process

Management of Change (MOC) under OSHA PSM is often poorly executed not due to lack of knowledge, but because it conflicts with operational realities. Production pressure, unclear definitions of change, weak field ownership, and procedural focus reduce effectiveness. Temporary and digital changes bypass controls, cumulative risk goes untracked, and approvals lack rigor. Without aligned incentives, clear boundaries, and post-implementation verification, MOC becomes a formality rather than a true risk control.

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  How to practically implement RBI for oil and gas production, gathering, and midstream facilities in the United States.

by Michael Hurley, 3/11/2026

Tags: API 580 API 581 Asset Performance Management Consequence Corrosion CUI Damage Mechanisms Data Collection Data Management Data Validation HSE Inspection Integrity Operating Windows Mechanical Integrity Process Safety Management Regulation Reliability Risk Analysis Risk Based Inspection Risk Management System Implementation Technology Work Process

This document presents a practical framework for implementing Risk-Based Inspection (RBI) and Mechanical Integrity (MI) programs for U.S. oil and gas production, gathering, and midstream facilities. It outlines lifecycle asset management practices aligned with API 510/570/653, API 580/581, PHMSA pipeline safety rules, and OSHA PSM to prevent loss of containment, detect degradation early, and maintain safe, reliable operations.

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  What Do Good Refining Corporate Cultures Look Like?

by Michael Hurley, 2/8/2026

Tags: API 580 API 581 Asset Performance Management Data Management HSE Human Factors Mechanical Integrity Process Safety Management RBMI Reliability Risk Risk Management Technology Training Value Work Process

In the refining industry, "culture" is often only analyzed after a failure occurs. However, a robust culture is defined by observable, repeatable behaviors and daily decisions made under pressure. This article outlines the seven practical attributes of high-performing refining organizations and demonstrates how alignment between leadership values and technical integrity creates a safer, more profitable operation.

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  Owner Management Support is Fundamental to Achieving What "Good Inspection" Looks Like

by Michael Hurley, 1/28/2026

Tags: Human Factors Inspection Mechanical Integrity

A "good inspection" is determined by whether an organization allows the truth about equipment condition to surface and then acts on it. While NDE methods and codes are important, they cannot compensate for weak ownership. This post explores how management defines the purpose of inspection, controls quality variables like scope and follow-up, and establishes the psychological safety necessary for true risk identification.

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  Execution Failures: The Main Cause of PSM Loss-of-Containment

by Michael Hurley, 1/21/2026

Tags: Asset Performance Management Mechanical Integrity Process Safety Management Risk Management

Investigations by the CSB and industry standards like API RP 754 reveal that the majority of loss-of-containment events are preventable through disciplined execution. While degradation mechanisms are often well understood and corrective actions identified, disasters frequently occur because repairs are delayed or inspections are deferred. This post explores how organizational accountability and robust governance can prevent these systemic breakdowns in PSM execution.

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  What Does "Good" Actually Look Like in Inspection?

by Michael Hurley, 1/14/2026

Tags: Damage Mechanisms Inspection Mechanical Integrity Probability

In mechanical integrity, we often confuse activity with assurance. A thick report or "100% coverage" means nothing if the inspection tool cannot "see" the damage morphology. This post explores what "good" inspection actually looks like by shifting the focus toward meaningfully reducing uncertainty. Learn the critical questions every program must answer and how to align NDE physics with specific damage mechanisms to prevent loss-of-containment events.

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  Got Out of 2025 with Only 9 U.S. Refinery Fires and Explosions - A Safety Checkpoint Worth Noting

by Michael Hurley, 1/7/2026

Tags: Mechanical Integrity Process Safety Management Regulation Risk

In 2025, the U.S. refining industry recorded approximately nine publicly reported fires and explosions. Notable events at Chevron’s El Segundo facility and HF Sinclair’s Navajo refinery underscore the persistent risks associated with mechanical failure and process safety gaps. This report analyzes why these statistics, though seemingly modest, demand a continued focus on maintenance and hazard identification to prevent future high-consequence events.

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  Replacing Internal Visual Inspection with Non-Intrusive Techniques in Refineries: Practical Recommendations

by Michael Hurley, 12/17/2025

Tags: API 580 API 581 Damage Mechanisms Inspection Mechanical Integrity Risk Risk Based Inspection

While Risk-Based Inspection (RBI) promised to reduce intrusive vessel entries, corporate risk aversion and rigid API standards have hindered progress. This post examines why internal visual inspection (IVI) remains the standard despite its human-factor limitations. We analyze the Probability of Detection (POD) for advanced NII technologies - including PAUT, PEC, and Corrosion Mapping - to propose a roadmap for achieving technical and regulatory equivalency in refinery asset integrity.

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  Why Companies Prioritize Other PSM Elements Over Mechanical Integrity

by Michael Hurley, 12/10/2025

Tags: Mechanical Integrity Process Safety Management Regulation

Mechanical Integrity (MI) is one of the most critical elements for preventing catastrophic events, yet it is routinely identified as one of the weakest in Process Safety Management (PSM). This article details 10 realistic reasons - from economic pressure and production bias to leadership knowledge gaps and the invisibility of degradation - why organizations chronically deprioritize MI work over other, more administrative PSM elements. Discover why companies focus on paper compliance instead of asset integrity.

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  Why is Mechanical Integrity So Important to Process Safety Management?

by Michael Hurley, 12/3/2025

Tags: API 580 API 581 Damage Mechanisms Mechanical Integrity Process Safety Management Regulation Risk Management

Mechanical Integrity (MI) is the crucial foundation of Process Safety Management (PSM). Major accidents overwhelmingly result from equipment failures like ruptured vessels or corroded piping. This post details eight essential reasons why a robust MI program is vital, including preventing loss of containment , ensuring safeguards function as designed , and meeting mandatory OSHA and EPA compliance.

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  Are U.S. Refinery Incidents Increasing? A Clearer Look at the Data, the Debate, and When the Trend Began

by Michael Hurley, 11/26/2025

Tags: Mechanical Integrity Regulation Risk Management

Public data suggests U.S. refinery fires and explosions have increased significantly since 2018, with some analyses showing a tripling of incidents. However, industry process safety metrics indicate improvement. This article explores the evidence, why the datasets conflict, and the start of the upward trend.

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  Why We Still See Refinery Fires - More Than 30 Years After OSHA 1910.119

by Michael Hurley, 11/20/2025

Tags: HSE Process Safety Management Regulation Risk Management

Despite OSHA's 1992 Process Safety Management (PSM) standard, refinery and chemical plant fires continue to make headlines. This post breaks down the seven systemic reasons why these incidents persist. We explore how mere compliance, aging infrastructure, weak safety culture, and reactive risk management prevent the elimination of catastrophic risks.

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  PHMSA vs OSHA for Hydrocarbon Facilities

by Michael Hurley, 11/12/2025

Tags: Mechanical Integrity Process Safety Management Regulation

Hydrocarbon facilities in the U.S. frequently face overlapping regulation from the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Occupational Safety and Health Administration (OSHA). While PHMSA primarily governs transportation safety via pipelines (49 CFR 190-199), OSHA focuses on worker safety and health within facilities, including Process Safety Management (PSM). This post clarifies their distinct scopes, common jurisdictional boundaries (e.g., at the first valve inside a facility), and provides tips for operators to integrate their compliance programs.

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  Why Moving to RBI Makes Sense - No Matter Where You Start

by Michael Hurley, 11/5/2025

Tags: Mechanical Integrity Process Safety Management Risk Based Inspection Risk Management

Discover how transitioning to a Risk-Based Inspection (RBI) approach can deliver real value and significant cost savings over traditional time/condition-based Mechanical Integrity (MI) programs. We use a simple 100-vessel example to show a potential $645,000 savings per inspection cycle and discuss how RBI accelerates compliance and prioritizes safety-critical tasks.

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  Leveraging AI to Accelerate Data Collection in Risk-Based Inspection Projects

by Stephen Elmer, 10/27/2025

Tags: API 580 API 581 Data Analysis Data Collection Data Management Data Migration Data Validation Risk Based Inspection Technology Value

Data collection is an RBI project bottleneck, often taking a very significant percentage of total effort due to manual interpretation of old, varied engineering documents. AOC developed AI-driven tooling to automatically extract, classify, and normalize this data, achieving a very high accuracy and significantly streamlining the process for faster, more reliable RBI implementation.

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  Proposal for Individual Damage Mechanism Risk Calculation in API 581

by Michael Hurley, 10/22/2025

Tags: API 581 Mechanical Integrity Process Safety Management Risk Analysis Risk Based Inspection Risk Management Technology

In 2021, I published a proposed change to the API 581 PoF calculation. While I believe API 581 is solid as a recommended practice, I believe that inspection planning can be further optimized and fine-tuned to adapt to organizational needs. Since then, the original article has prompted a variety of comments and questions and so I have rewritten the original article for, hopefully, a little more clarity, and I have consolidated the top questions along with my comments.

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  API 580 vs API 581: Which RBI Approach Is Right For You?

by John Dickerson, 10/15/2025

Tags: API 580 API 581 Risk Based Inspection

Deciding between API 580 and API 581 for Risk-Based Inspection? This guide helps you choose the right approach for your site's unique needs. Learn whether the qualitative, experience-based framework of API 580 or the data-driven, semi-quantitative methodology of API 581 is the best fit for your facility.

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