How Long Do I Have to Address Mechanical Integrity Recommendations? | Blog No. 78

For those managing process safety, one of the common questions we hear is:

How long do we have to remediate recommendations from a 5-Year Mechanical Integrity Audit (MIA)? 

Unlike process hazard analyses (PHA) and compliance audits, which have clearer regulatory timelines in some states, the answer for mechanical integrity is more nuanced.

Regulatory Guidance

While specific deadlines for mechanical integrity inspections/audits are not explicitly stated in federal process safety regulations, there are clear expectations for addressing deficiencies under OSHA’s Process Safety Management (PSM) standard and EPA’s Risk Management Program (RMP).

OSHA PSM Regulation – Title 29 CFR §1910.119(j)(5)

"Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means are taken to assure safe operation."

EPA RMP Regulation – Title 40 CFR §68.73(e)

"Equipment deficiencies. The owner or operator shall correct deficiencies in equipment that are outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means are taken to assure safe operation."

These regulations emphasize that deficiencies must be corrected before further use or in a safe and timely manner to ensure continued safe operation.

It is worth noting that the International Institute of All-Natural Refrigeration (IIAR) does not provide guidance on how long facilities have to resolve mechanical integrity recommendations.

Half-Life Rule

Many states follow federal PSM and RMP regulations, but some, such as California, have additional guidance through the CalARP program. In California, timelines for other PSM-related activities provide useful benchmarks:

• PHA recommendations – up to 2.5 years

• Compliance audit recommendations – up to 1.5 years

  
  

Although these specific timeframes are unique to California, applying the “half-life” approach as a guiding principle can help facilities in any state establish reasonable completion deadlines for mechanical integrity recommendations. Just as the PHA is a 5-year activity with a 2.5-year timeline for resolving recommendations, 5-year mechanical integrity audit recommendations should be resolved no later than 2.5 years later.

Guiding Principles

Since there is no firm deadline for mechanical integrity recommendations, here are some guiding principles for prioritization:

1. Immediate Hazards – Address critical issues right away, particularly if there is an active leak, equipment is operating outside its design or safety limits, or the deficiency poses some other immediate threat to safety or compliance.

   
   

2. Applying a Risk-Based Approach – Many companies align their resolution timeline with PHA practices. Since PHAs are reviewed every five years, it is reasonable to target resolving all MIA recommendations within 2.5 years.

   
   

3. Regulatory Expectations – While not explicitly stated in regulations, anecdotal experience with OSHA and EPA suggest that deficiencies should be addressed within one (1) year whenever feasible. If delays are unavoidable (e.g., replacing old pressure vessels without nameplates), regulatory agencies are typically amenable if all other recommendations have been addressed, and a clear capital improvement plan exists for addressing long-term deficiencies.

   
   

Adjusting Timelines for Corrosion, CUI, and NDT

Not all mechanical integrity findings demand immediate remediation. Corrosion, Corrosion Under Insulation (CUI), and Nondestructive Testing (NDT) timelines can be spaced out based on inherent risk and criticality of the affected piping or equipment. Some companies choose to adopt savvy categorizations based on resources provided by the Industrial Refrigeration Consortium. For example, corrosion can be classified as either minor or other-than-minor. CUI can be addressed by external indicators and the risk of the underlying piping or equipment. Finally, a risk-based approach (RBI) can also be applied to NDT. Instead of needing to perform NDT across the entire system, areas with greater inherent risk can be performed sooner than those areas of lesser inherent risk.

Conclusion

Addressing mechanical integrity recommendations requires a balanced approach—one that adheres to regulatory obligations while recognizing operational and financial constraints. While there is no fixed timeline, following these principles can help ensure that deficiencies are addressed in a timely, systematic, and regulatorily defensible manner.

For facilities in all states, leveraging industry best practices—such as addressing immediate hazards promptly, resolving general deficiencies within a reasonable time frame (e.g., 1-2.5 years), and prioritizing higher-risk issues—can provide a solid compliance framework.

If you're uncertain about a specific deficiency or need assistance in developing a compliance strategy, the Macha PSM team is here to help!