In an earlier post, I discussed maintaining compliance of hazardous area certified equipment, from a paper given by Emerson safety consultant, Bob Baker.
At the recent AIChE Spring National Meeting
Process Plant Safety Symposium, Bob gave an updated paper, Safety & Regulatory Compliance of Reconditioned Equipment (presentation).
He sums up the pressures that process manufacturers face:
Responding to challenges of seemingly unending reductions in capital and maintenance budgets, the process industry has increasingly turned toward the purchase of lower cost, recycled equipment including salvaged control valves and instrumentation.
The market for salvaged and reconditioned control valves expanded from onshore and offshore oil and gas producers in the early 1990s to onshore chemical, petrochemical and refiners today due in large part to declining maintenance budgets and financial pressure on small, locally engineered capital projects.
Unless appropriate equipment purchase specifications are specified and followed, exposure to potentially significant safety risks may occur when using salvaged, new-surplus, refurbished, or remanufactured equipment (considered “reconditioned” equipment):
Although it equipment may be acceptable from a functional perspective, depending on equipment age, repair history, application severity and other factors, such “reconditioned” equipment may be out of compliance with safety standards, or with manufacturer’s specifications as originally designed to applicable industry codes, for safe use in hazardous locations.
One of the U.S. Occupational Health and Safety Administration (OSHA)-accredited Nationally Recognized Testing Laboratory (NRTL) is FM Approvals. The paper notes that FM Approvals’ position for reconditioned and new-surplus instruments for use in hazardous locations:
It is FM Approvals’ position that only the original manufacturer of the Approved product or an FM Approved remanufacturer whose facilities are part of the FM Approvals follow-up audit program, can remanufacture a product and reissue the FM Approvals certification mark. Any suggestion, practice or inference to the contrary is wrong and must cease… Any salvaged, remanufactured or new surplus electrical instrument cannot be labeled or relabeled as FM Approved for use in a classified hazardous location unless the refurbishing/new surplus supplier entity is audited and approved by FM Approvals, LLC, for that specific type of instrument.
FM Approvals presented the issues, challenges, and its position at several safety symposiums in late 2006 and early 2007.
Bob offers this recommendation for process manufacturers:
Vendor qualification and technical awareness is critical, requiring initial education of all plant personnel associated with the specification, purchase, inspection or repair of reconditioned and new-surplus equipment. Further, ever-changing organizational structure and new personnel requires a sustained education program, including ongoing emphasis at safety meetings. End user issuance of specific corporate policy and guidance could be an effective method to appropriately emphasize and establish requirements for purchasing reconditioned equipment.
Regulatory organizations such as OSHA and EPA typically put the burden of sustaining compliance to safety and regulatory requirements on the end user.
If you are using or considering using “reconditioned” instrumentation in hazardous locations or “reconditioned” control valves in applications within your plant’s Process Safety Management (PSM) program, make sure to read the entire paper. Bob provides suggestions for vendor qualification requirements, suggests work processes, and describes the applicable standards.