13 entries found for "Process Safety Management"
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.
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.
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.
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.
The Top Three RBI Risks That Cannot Wait for a Budget Rebound
by Michael Hurley, 10/1/2025
Tags: CUI Inspection Mechanical Integrity Process Safety Management Regulation Risk Risk Analysis Risk Based Inspection Risk Management Value
When organizations face budget cuts, they may postpone projects, but certain risks are too critical to delay. This post highlights three such Risk-Based Inspection (RBI) risks that demand immediate attention: high-risk equipment, Corrosion Under Insulation (CUI), and overdue critical inspections. Acting now can safeguard people, assets, and the bottom line from costly failures.
A Practical Way to Incorporate the New PHMSA Underground Gas Storage Requirements Into your MI Program
by Michael Hurley, 3/11/2021
Tags: Damage Mechanisms Inspection Mechanical Integrity Process Safety Management Regulation Risk Analysis Risk Based Inspection Risk Management
PHMSA has out a new rule for underground natural gas storage facilities (UNGSFs). This is practical approach to incorporating gas wells into your mechanical integrity program with the rest of your surface and subsurface assets.
Plant Management 101: Common Work Processes
by Michael Hurley, 3/3/2021
Tags: Asset Performance Management Data Collection Data Validation Mechanical Integrity Process Safety Management Reliability Risk Management Training Work Process
This article deals with the dysfunctionality found in many refineries, chemical plants, and other production facilities. This can lead a facility to not reaching its value and reliability goals. One of the main reasons for this dysfunctionality is facility departments not using a common asset management work process.
Proposed API 581 Inspection Plan Optimization Example
by Michael Hurley, 2/4/2021
Tags: API 581 Mechanical Integrity Process Safety Management Risk Analysis Risk Based Inspection Risk Management Technology
This article deals with a proposal for a risk analysis option that allows for individual damage mechanism risk calculation. This is an example of how it can be applied and how it domonstrates value.
Proposed API 581 Inspection Plan Optimization
by Michael Hurley, 1/27/2021
Tags: API 581 Mechanical Integrity Process Safety Management Risk Analysis Risk Based Inspection Risk Management Technology
This article deals with a proposal for a risk analysis option that allows for individual damage mechanism risk calculation. This allows for these individual damage mechanism risks to be compared to a risk target that when reached generates an inspection task with its own due date.
RBI Value: Both Transitioning And From The Start
by Michael Hurley, 1/21/2021
Tags: Mechanical Integrity Process Safety Management Risk Based Inspection Risk Management
This article deals with the value of going directly to an Risk Based Inspection (RBI) program from nothing or transitioning from a time/condition based program and demonstrates that an RBI program is the efficient use of resources.
Possible PHMSA and OSHA Jurisdictional Clarity
by Michael Hurley, 1/14/2021
Tags: Mechanical Integrity Process Safety Management Regulation
PHMSA has out for comment, draft document information, that clarifies its jurisdiction in relation to OSHA for Midstream Processing Facilities.
Qualitative RBI of a Commercial Refrigeration System
by Rob Sladek, 8/7/2018
Tags: Consequence Probability Process Safety Management Risk Risk Based Inspection
How the application of qualitative RBI helped a client prioritize equipment damage mitigation in order to effectively scope a refurbishment project and achieve their system reliability goals. This scenario highlights a significant problem for some refrigeration system owner/users who may be maintaining their assets as prescribed but are unaware of the damage mechanisms that could affect the reliability of their assets and safety of their personnel.
Process Safety Management (PSM) and Commercial Refrigeration
by Mike Hurley, 7/18/2018
Tags: Process Safety Management
Organizations that have commercial refrigeration facilities need to be aware of new OSHA Process Safety Management (PSM) regulations. Since these facilities are something of an outlier, when compared with chemical processing and refineries, it may not be readily apparent. However, anyone with large quantities of anhydrous ammonia at their facilities needs to prepare for potential NEP audits.
Asset Optimization is the authority on asset integrity solutions that align your people, process, and technology with unmatched returns across your enterprise.
Consulting Activities
Contact Us
United States
16000 Barkers Point LaneSuite 105
Houston, TX 77079
Phone: +1 (281) 909-7333
Email: info@aoccorp.com
Europe
CATCH Facility,Redwood Park Estate,
Stallingborough,
Grimsby, North East Lincolnshire,
DN41 8TH, United Kingdom
Phone: 00 44 (0) 1469 552875
Copyright © 2024 Asset Optimization Consultants, Inc. All Rights Reserved.