Depending on age, repair history, application severity and other factors, process control equipment may be out of compliance with safety standards or with manufacturer's original design specifications for safe use in hazardous locations. If equipment does not meet the manufacturer's technical specifications for the current service, there are potential implications to the Process Safety Information and Mechanical Integrity elements of OSHA's Process Safety Management (PSM) Standard (29 CFR 1910.119) and EPA's Risk Management Program rule (RMP) (40 CFR 68). Of particular concern is potential risk of “loss of containment” of aged piping components such as salvaged and refurbished / remanufactured valves that are re-introduced into process plants without re-verification of pressure containment components.

Further implications exist with respect to reconditioned electrical/electronic instrumentation used in hazardous areas, as covered by OSHA Standard (29 CFR 1910.307). These regulations require end-users to verify equipment compliance when installed in their process areas. Special attention should be paid by inspection, operations, engineering, maintenance, and procurement personnel in better understanding and addressing the potential safety and regulatory compliance issues. Data to date indicates several thousand such instruments installed per year that may no longer be approved for use in hazardous locations, yet purchasers and suppliers of this equipment are unaware due to original approval certifications left on the equipment nameplates when resold.

Included will be recommendations where any anticipated application of non-conforming equipment could be identified, and appropriate MOC evaluations could be undertaken. The growing presence of these issues also present potential areas of interest during plant acquisition due diligence.