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API RP 578 PMI 2nd edition, OSHA NEP

API RP 578, 2nd edition, has been balloted, reviewed and approved. API has advised that it is being prepared for publication by mid-year 2009.

This RP is now referred to by OSHA in their National Emphasis Program Directive CPL 03-00-004 for audits of refineries and chemical plants. An audit question for PMI, (summarized) below:

"Does the employer ensure that replacement piping is suitable for its process application?"
If no, possible violations include:
(119(j)(4)(ii) - the employer did not follow *RAGAGEP when it failed to conduct positive material identification (PMI) testing for existing piping systems. (An example RAGAGEP for PMI testing includes API RP 578. CSB (Chemical Safety Board) Safety Bulletin- Positive Material Verification: Prevent Errors During Alloy Steel Systems Maintenance."


*RAGAGEP= Recognized and generally acceptable good engineering practices.