There should be a policy in place and enforced by

management at each operating site of not allowing

equipment and repair recommendations to become overdue
for inspection and handling. Such a practice goes a long
way toward increasing the credibility of the inspection
efforts at each operating site, as well sending the message
that FEMI is just as important as other plant priorities. Of
course, in order to get to that point, inspection scheduling,
data quality, data analysis, and record keeping have to be of
sufficient quality and credibility, that ignoring inspection
schedules actually increases risk, as well as putting the
operating site in violation of codes and standards and
potential jurisdictional regulations.

At the same time, fixed equipment and inspection

recommendations that, for some valid reason, cannot be
inspected or completed by their due dates can sometimes be
deferred by using a valid risk-based deferral process. My
experience indicates that a structured risk assessment for
potential deferrals of scheduled inspections is far better that
the old ways that involved either (1) someone in inspection
drawing an arbitrary “line in the sand” and saying
“Absolutely no deferrals”, or (2) someone else in the
organization just making arbitrary decisions (without
inspection involvement or approval) that a scheduled
inspection or inspection recommendation will simply be
allowed to become overdue without understanding the risks
associated with such arbitrary “hand waiving” of the due
dates. In my experience, the work process for deferring
equipment inspections and/or inspection repair
recommendations should be rigorous, well documented,
risk-based and not be so simple and easy that the site ends
up with such a long list of deferrals that the process
becomes nearly equivalent to just letting equipment and/or
inspection recommendations become overdue. A best
practice for such deferrals is to require the approval of a
site senior manager before equipment or inspection
recommendations are allowed to be deferred. That level of
approval will usually keep the process from being abused. 
Such a deferral process is currently in effect at many
operating sites and has now been approved by the API
Inspection Subcommittee and will be part of the next
editions for API 510 [1] and 570 [2]. The following is some
quoted material from the approved 10th edition
(publication pending) of API 510. Definitions: 

 “Overdue inspections: Inspections for in-service

vessels that are still in operation, that have not been
performed by their due dates documented in the
inspection plan, which have not been deferred by a
documented deferral process.”
 “Overdue inspection
recommendations: Recommendations for repair or
other mechanical integrity purposes for vessels that
are still in operation that have not been completed by
their documented due dates, which have not been
deferred by a documented deferral process.” 

In the body of the 10th edition of the API 510 Code, the
deferral process is addressed this way: [Quote] 
“Inspection tasks for equipment and PRDs (not set by RBI)
that cannot be performed by their due date can be risk-
assessed and deferred for a specific period of time, where
appropriate. A deferral procedure shall be in place that
defines a risk-based deferral process, including a
corrective action plan and deferral date, plus necessary
approvals, if inspection of a piece of pressure equipment is
to be deferred beyond the established interval. That
procedure should include: (1) concurrence with the
appropriate pressure equipment personnel including the
inspector and appropriate owner/user management
representative, (2) any required operating controls needed
to make the extended run, (3) need for appropriate non-
intrusive inspection with NDE, if any, as needed to justify
the tempo- rary extension, and (4) proper documentation of
the deferral in the equipment records.

Notwithstanding the above, an inspection or PRD servicing

interval may be deferred by the Inspector, without other
approvals, based on a satisfactory review of the equipment
history and appropriate risk-analysis, when the period of
time for which the item is to be deferred does not exceed 10
percent of the inspection/servicing interval or six months,
whichever is less.

For equipment with risk based inspection intervals, the

existing risk assessment should be updated to determine the
change in risk that may exist by not doing the originally
planned inspection. A similar approval process used for
equipment with non-RBI intervals should be used to
document the change in risk levels.

Deferrals need to be completed and documented before the

equipment is operated past the scheduled inspection due
date; and owner/user management apprised of the
increased risk (if any) of temporarily operating past the
scheduled inspection due date. Pressure equipment
operated beyond the inspection due date without a
document- ed and approved deferral is not permitted by
this code. The deferral of scheduled inspections should be
the occasional exception not a frequent occurrence.” [End
quote] 
With regard to deferrals of inspection repair
recommendations, the body of the API 510 Code deferral
process is addressed this way: [Quote]

“Inspection repair recommendations that cannot be

completed by their due date can be deferred for a specific
period of time, if appropriate, by a documented change in
date of required completion. The deferral of the due date
shall be documented in the inspection records and have the
concurrence with the appropriate pressure equipment
inspection personnel including the inspector and the
inspection supervisor. Inspection recommendations that
have not been completed by the required due date without a
documented and approved change of date are not permitted
by this code and are considered overdue for completion.
The deferral of inspection recommendations should be the
occasional exception not a frequent occurrence. Equipment
must remain within the limits of the minimum required
thickness as determined in this Code or by other
engineering evaluation during the period of deferral.”
[End quote] 
And finally with regard to reviewing and potentially
changing of inspection repair recommendations, the body
of the API 510 Code addresses the issue this way: [Quote] 

“Inspector recommendations can be changed or deleted

after review by pressure vessel engineer or inspection
supervision. If that is the case, inspection records shall
record the reasoning, date of change/deletion and name of
person who did the review.” [End quote] 

Do you keep your management informed of equipment that

is overdue for inspection? Does your plant management
practice a strict “no overdue” equipment policy? Does your
site have a structured deferral process for equipment and/or
inspection recommendations that may become overdue that
is at least as good as the new sections that will be in the
10th edition of API 510?