[MCIC Safety] PSM Question

[[MCIC] Jim Kuszaj]

Hope all you safety experts out there are doing well. If you don't 
mind taking a few minutes, we have a question or two for you.

Within the Mechanical Integrity section under the Process Safety 
Management (PSM) regulations Federal OSHA gives requirements for 
documentation of tests/inspections, but gives no documentation 
retention time.  However an interpretation letter written on 
9/16/1996, attached, states

"In order to demonstrate compliance with paragraph 1910.119(j), and 
to meet the purpose of ongoing mechanical integrity, the 
documentation required under paragraph 1910.119(j)(4)(iv) must be 
kept for the lifetime of the process."

We think this is a bit excessive and that a retention period of 5 
years well documents compliance. Perhaps going longer only for 
deviations and corrective actions. Has anyone had a communication 
from NCOSH either through a discussion or an inspection wherein a 
document retention period was given? Are you keeping this and other 
PSM-related documentation electronically or with hard-copy or both?

Thanks, Dick

Richard McDonald

Shurtape Technologies, LLC

Safety Director

828-267-8228

828-851-0774 (mobile)

877-859-9747 (fax)