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.
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.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.by Michael Hurley, 3/3/2026
Tags: API 580 API 581 Corrosion CUI Damage Mechanisms HSE Inspection Mechanical Integrity Process Safety Management RBMI Regulation Risk Risk Based Inspection Risk Management Technology Work Process
Confirm equivalent inspection via a 10-step, 8-gate process aligned with API 580/581 to ensure defensible RBI risk reduction.by Michael Hurley, 2/25/2026
Tags: API 580 API 581 Asset Performance Management Consequence Corrosion CUI Damage Mechanisms Data Analysis Data Management HSE Inspection Integrity Operating Windows Mechanical Integrity Process Safety Management Risk Risk Based Inspection Risk Management Safe Operating Limits System Implementation Value Work Process
Reliability improves when priorities are truly enforced: safety first, environmental protection second, production third.by Michael Hurley, 2/17/2026
Tags: API 580 API 581 Corrosion CUI Damage Mechanisms Data Analysis Data Collection Data Management Data Migration Data Validation Inspection Integrity Operating Windows Mechanical Integrity Probability Process Safety Management Regulation Risk Risk Analysis Risk Based Inspection Risk Management Skills Validation System Implementation Technology Training Value Work Process
Is your RBI contractor truly qualified or just proficient with software?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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.