As time goes by, technology moves forward, lessons are learned and industry requirements evolve. Personnel come and go, and facilities are bought and sold. The by-products of this evolution are changes to both industry best practices and corporate requirements.
While change can improve safety and reliability, it also complicates the already challenging task of selecting the right valve. Replacement in-kind is not always the correct solution. Add to that complication the looming reality of today’s gap in industry expertise, and it’s easy to see why corporations and facility engineers need and want guidelines to help them make consistent decisions. To provide this guidance, many corporations go in search of best practice collections.
WHAT’S A BEST PRACTICE?
A best practice can be defined as a technique or methodology that, upon rigorous evaluation through experience and research, demonstrates success and can be replicated. Industry standards, such as documents produced by the American Petroleum Institute (API), provide minimum industry requirements. Recognized and generally accepted good engineering practices (RAGAGEP) requires these practices meet minimum industry requirements, but they may be more stringent based on the experience and unique attributes of a facility or corporation. Best practices typically use or direct users to a published industry standard to set baseline requirements and then clarify options or provide additional requirements above the industry standard based on company preferences and experience.
A best practice collection includes sections of documents for each area of expertise needed within a corporation such as safety systems, pressure vessels, inspection, mechanical integrity, etc. Of all the sections, the subject of piping and valves is typically one of the most complicated and debated subjects because of the sheer quantity of components needed for a piping system. Because of this, it’s one of the most customized subjects from facility to facility. In addition to documents to define piping and valve requirements, the majority of best practice collections include a set of piping classes—pre-engineered groupings of components and valves selected for a given service with specific design conditions.
The two most common options considered are general industry best practices and engineering, procurement and construction (EP&C) firms’ best practices. Unfortunately, while general industry solutions are typically affordable, complications arise when solutions do not fully align with the corporation’s philosophy. When that happens, separate documents need to be created and distributed throughout the organization because general industry standards themselves can’t be customized. The end result is an internal document that references a general industry best practice that then references an industry standard. This is challenging not only for a user to understand but also for an organization to maintain over time.
The other option most often used—EP&C firms’ best practices—might appear at first glance to be an ideal solution because they are usually in line with the current RAGAGEP requirements. However, once the project reaches an end, these documents are rarely modified or kept up to date. As a result, after a few years have passed, facilities are often left with multiple sets of thousands of pages of detailed best practices that may or may not be in alignment with current RAGAGEP. The onus is then put on the engineer to make correct decisions despite changing industry and corporate requirements.
A third option is to develop and maintain internal, corporate best practices.
WHAT AN INTERNAL PROGRAM CAN DO
Internal best practices provide the ability to define requirements in alignment with the corporate risk profile and provide a forum to capture and transfer knowledge throughout the organization. As a result, the organization benefits from improved facility safety, mechanical integrity and efficiency over the long term.
Unfortunately, while customizable internal best practices are the ideal solution, many organizations have tried and failed because of the amount of time and expertise needed to develop and maintain an internal collection. In addition, efforts to develop internal practices fail because of the overwhelming amount of legacy information typically present at a site. Included in this legacy information are hundreds or even thousands of legacy piping classes and valve data sheets for each facility in the organization. To compound the problem, each of these legacy piping classes, and sometimes specific valves, exist on the facility’s drawings. This makes deciding to consolidate and switch systems to a standard set of master corporate piping classes difficult because of the time involved and the incorrect assumption that adopting a new system will require thousands of site drawings be redrawn.
WHAT OSHA RECOMMENDS
In June 2015, the Occupational Safety and Health Administration (OSHA) published new guidance for industry standard 29 CFR Part 1910.119, Process Safety Management of Highly Hazardous Chemicals with interpretations for Process Safety Management (PSM) and RAGAGEP, including clarifications and interpretations regarding:
- What RAGAGEP is and what its sources are
- “Shall” vs. “should”
- The use and acceptance of internal employer documents as RAGAGEP
- Considerations for maintaining compliance with the standard
In this recently published memorandum, OSHA provides not only clarification that appropriate internal standards are considered acceptable RAGAGEP documents, but also why OSHA recommends facilities develop and use internal standards.
The memo states that facility internal standards can serve a number of legitimate purposes, including:
- Translating the requirements of published RAGAGEP into detailed corporate or facility implementation programs and/or procedures
- Setting requirements for unique circumstances for which no published RAGAGEP exists
- Supplementing published RAGAGEP that only partially or inadequately address the employer’s needs
- Controlling hazards more effectively than available codes and standards
- Addressing hazards when the codes and standards used for existing equipment are outdated and no longer describe good engineering practice1
Internal best practices also offer these additional benefits:
- Promote safety, manage risk and improve reliability
- Capture corporate memory
- Transfer knowledge
Regarding that first point, internal corporate best practices force an organization to discuss, determine and define the corporation’s requirements. In doing this, organizations can address the overall process of life-cycle management (LCM), which can be defined as the process of managing the entire life cycle of assets including design, construction, in-service use, repair if required and retirement. The LCM process for fixed pressurized equipment, including pressure vessels, piping and tankage is shown in Figure 12.
This chart shows that identifying the initial damage mechanism and making design decisions during the early stages of equipment and component life can affect the amount of damage later in life (when paired with in-service inspection techniques and programs). Depending on the amount of damage, a fitness-for-service assessment can indicate whether to continue to operate, repair or replace the piece of equipment. Organizations using a customizable internal best practice collection can improve reliability by taking a lessons-learned approach when unanticipated damage is identified and can modify future designs to prevent the same damage.
Regarding corporate memory, this can be defined as the total body of knowledge, comprised of both documented and undocumented memories and experiences, created over the course of an individual organization’s existence. An internal best practice collection provides an ideal forum to document this memory and capture lessons learned as the organization’s experience grows.
Once corporate memory is placed in a common location accessible to everyone in the organization, the knowledge can be transferred. For organizations with multiple facilities, this information is transferred not only from employee to employee, but also from facility to facility. In this way, an organization can take advantage of internal knowledge sharing across sites, and a lesson learned at one facility can be used to prevent another facility from making the same mistake. This concept is vital to industry as it nears a potential gap in industry expertise. It can ensure that the skills of an organization’s most experienced employees are not lost as these members leave the organization.
To illustrate the above concepts, consider this example. An organization consistently finds cracking in the grooves of its ring-type joint (RTJ) flanged valves. While RTJ flanges are an acceptable industry design and have historically been a common design practice for this organization, the cost of repair or replacement from this unanticipated damage shows a need for a change in corporate philosophy to use raised-face (RF) flanges instead. This corporate memory was captured by modifying the internal best practice regarding flange connection requirements, and the master set of corporate piping classes was then modified to remove RTJ flanged valves and replace them with RF flanged valves. The corporation then transferred this corporate knowledge throughout the organization, which led to modified designs, improved reliability and corporate cost savings because of reduced unanticipated damage with RTJ flange connection points.
HOW TO DEVELOP AN INTERNAL PROGRAM
Corporations typically have a number of options when developing an internal best practices collection. The organization can write new documents, write overlays to general industry best practices, update outdated legacy collections, consolidate legacy collections, purchase an up-to-date collection from a third party or use a combination of these solutions. The most important factor to consider before making a decision is to remember a best practice collection needs to be continually updated to align it with changing industry requirements so it is considered an acceptable RAGAGEP solution.
This need for an update means the organization should consider not only the time and effort involved to create the collection, but also the long-term investment required to maintain it. For this reason, it is vital that if a collection is purchased from a third party, the organization has the ability to customize and modify that collection over time.
As part of the corporate best practice collection, each organization should include and develop a single set of master piping classes. As with the overall collection, a decision needs to be made as to what the organization wants to use as a starting point, and piping classes have to be modifiable over time to maintain alignment with industry and corporate requirements.
As mentioned earlier, piping classes add a layer of complexity because the class name typically is added to the facility drawings. To avoid the time and effort of updating all these facility drawings, a corporation can perform a piping cross-reference to relate the legacy piping classes to the new set of master piping classes. This cross-reference is a matrix relating similar legacy piping classes. Before performing a piping cross-reference, an organization should define its corporate requirements for piping systems, such as which valve trims should be used for which service, when valves will require NACE requirements, what the minimum corrosion allowances are per material, etc. Such action is needed prior to executing a piping cross-reference because it is important to relate the legacy piping class to the class meeting the current requirements rather than the original design of the legacy class. For example, if a legacy piping class for an Aggressive Environmental Service (AES) did not require NACE valves, but new corporate philosophy does require them, the legacy piping class should be related to a master piping class requiring NACE valves.
To maintain a collection, a subject matter expert (SME) should be assigned to each document and to the piping classes. The organization should assign rules for reviewing and reaffirming the content to maintain alignment with RAGAGEP and industry best practices, and a multi-year review schedule should be developed to support this effort.
Because maintenance can be time consuming and requires the most experienced and usually busiest personnel, it may be advantageous for the SMEs to use additional internal and external expertise to maintain the collection. It is also the reason why many organizations choose to purchase a customizable best practice collection from a third-party vendor that will keep it up to date, allowing the organization’s employees to focus on other tasks until they are needed to help with updates.
Change in technology, requirements and people is inevitable for all organizations so they need the best tools for keeping up with that change. While it takes a commitment from the organization to develop and maintain internal best practices, the end result is a corporate tool to provide guidance to the employees who make critical decisions each and every day, including knowing exactly which valve to order.