The Third Benefit of Damage Mechanism Reviews

Contributed by: Dheerajkumar R Narang

Federal agency OSHA regulates and enforces several health and safety standards in the United States under Title-29, Subtitle-B, Chapter-XVII, Part-1910. Damage mechanism review(s) play a crucial role in achieving successful compliance with a few of these health and safety standards. However, the DMR process alone cannot ensure full compliance with relevant health and safety standards, as other engineering, non-engineering, administrative, and management aspects of regulatory compliance must also be considered by original equipment manufacturers and operational facilities.

This article highlights the relevant federal OSHA health and safety standards that can successfully interface with the damage mechanism review (DMR) process. 

Subpart H, 29 CFR 1910.119 Titled Process Safety Management of Highly Hazardous Chemicals 
The first article in the series of DMR articles explains the importance of DMR process for compliance with the OSHA PSM standard elements in detail.

Subpart D Walking-Working Surfaces 
The 29 CFR 1910 Subpart D titled Walking-Working Surfaces covers the following relevant regulations that can potentially interface with the DMR process.

• 29 CFR 1910.23 Ladders
• 29 CFR 1910.24 Step bolts and manhole steps
• 29 CFR 1910.25 Stairways
• 29 CFR 1910.26 Dock boards
• 29 CFR 1910.27 Scaffolds and rope descent systems
• 29 CFR 1910.28 Duty to have fall protection and falling object protection
• 29 CFR 1910.29 Fall protection systems and falling object protection—criteria and practices

The DMR process can identify potential mechanical or operational damage mechanisms, with failure modes such as buckling and sagging, which assist mechanical designers in assessing metallurgical options and improving design (intended load-bearing capacity) for various product applications, such as ladders, stairways, and scaffolding. The inspection test plan and quality control procedures heavily depend on the choice of material; therefore, the feasibility of a manufacturing process for a specific material also depends on the damage mechanism review process. Additionally, the DMR process can identify potential 'what-if' failure scenarios, enabling the proactive development of inspection, maintenance, and operational plans for walking-working surface mechanical products.

Subpart F Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms
The 29 CFR 1910 Subpart F titled Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms covers the following relevant regulations:

• 29 CFR 1910.66 Powered platforms for building maintenance
• 29 CFR 1910.67 Vehicle-mounted elevating and rotating work platforms
• 29 CFR 1910.68 Manlifts

Here, the DMR process can aid in the design, construction, inspection, and maintenance of powered, vehicle-mounted platforms and man lifts. It identifies potential mechanical or operational damage mechanisms with applicable failure modes, assisting mechanical designers in assessing metallurgical options, applying relevant failure theories, and improving the design (intended load-bearing capacity) of work platforms and man lifts.

Subpart H Hazardous Materials
This section covers the following relevant regulations that can interface with the DMR process.

• 29 CFR 1910.101 Compressed gases (general requirements)
• 29 CFR 1910.102 Acetylene
• 29 CFR 1910.103 Hydrogen
• 29 CFR 1910.104 Oxygen
• 29 CFR 1910.105 Nitrous oxide
• 29 CFR 1910.106 Flammable liquids
• 29 CFR 1910.107 Spray finishing using flammable and combustible materials
• 29 CFR 1910.109 Explosives and blasting agents
• 29 CFR 1910.110 Storage and handling of liquefied petroleum gases
• 29 CFR 1910.111 Storage and handling of anhydrous ammonia
• 29 CFR 1910.119 Process safety management of highly hazardous chemicals
• 29 CFR 1910.120 Hazardous waste operations and emergency response

The DMR process can aid in the design, construction, inspection, and maintenance of pressure equipment, piping, and other fluid containment packaged equipment for compressed gases such as acetylene, hydrogen, oxygen nitrous oxide, and flammable liquids. It is critical to perform damage mechanism reviews for process plant and pipeline assets containing, storing, and transporting anhydrous ammonia, liquefied petroleum gases, and hazardous chemicals. The flammable and combustible materials used in spray finishing, storage, and handling of explosives and blasting agents require extensive material selection assessment which is an important step in the damage mechanism review process.

Figure 1. Storage and Handling of Pressure Equipment, Tanks at a Process Plant

Specifically, all types of pressure equipment, piping, and other fluid containment packaged equipment used across various industries are typically designed, constructed, inspected, and maintained in accordance with applicable ASME code sections, such as ASME Sections II, IV, and VIII for equipment, and the ASME B31 series for process and utility piping. Additionally, API Recommended Practices (RPs) provide more detailed guidance on the design, construction, inspection, repair, and maintenance of these plant assets.

Figure 2. Process Equipment with Three Damage Mechanisms

Moreover, DMR process can aid in compliance with the other global regulations and regional standards listed in each subsection of Subpart H under 29 CFR. For example, DMR process can aid in compliance with relevant Compressed Gas Association (CGA) pamphlets cited by the compressed gas regulation subsections from 29 CFR 1910.101 through 29 CFR 1910.105. Also, DMR process can aid significantly in complying with the Department of Transportation 49 CFR Subpart B Chapter I (Pipeline and Hazardous Materials Safety Administration, Department of Transportation) regulations cited by 29 CFR 1910.110 (liquefied petroleum gases) and 29 CFR 1910.111 (anhydrous ammonia) in Subpart H.

READ: The Second Benefit of Damage Mechanism Reviews

Subpart L Fire Protection
The 29 CFR 1910 Subpart L titled Fire Protection covers the following regulations that can potentially interface with the DMR process.

Portable Fire Suppression Equipment

• 29 CFR 1910.157 Portable fire extinguishers
• 29 CFR 1910.158 Standpipe and hose systems

Fixed Fire Suppression Equipment

• 29 CFR 1910.159 Automatic sprinkler systems
• 29 CFR 1910.160 Fixed extinguishing systems, general
• 29 CFR 1910.161 Fixed extinguishing systems, dry chemical
• 29 CFR 1910.162 Fixed extinguishing systems, gaseous agent
• 29 CFR 1910.163 Fixed extinguishing systems, water spray and foam

The DMR process can aid in the design, construction, inspection, and maintenance of both portable and fixed fire suppression equipment. It identifies potential mechanical or operational damage mechanisms with applicable failure modes, helping mechanical designers assess metallurgical options, apply relevant failure theories, and improve the design (intended fire resistance in various conditions) of the fire suppression equipment.

Subpart M Compressed Gas and Compressed Air Equipment
The 29 CFR 1910 Subpart M titled Compressed Gas and Compressed Air Equipment covers the relevant regulation 29 CFR 1910.169 titled Air Receivers that can potentially interface with the DMR process.

Like Subpart H, the DMR process can help identify potential mechanical, process or operational damage mechanisms with applicable failure modes that can help equipment designers and engineers with assessing various metallurgical options, applicable failure theories and improve the design, operation, inspection, and maintenance of all types of compressed gas and air equipment that will fall under the 29 CFR Subpart M regulation.

Figure 3. Compressed Gas Equipment

Subpart N Materials Handling and Storage
The 29 CFR 1910 Subpart N titled Materials Handling and Storage covers the following:

• 29 CFR 1910.176 Handling materials - general
• 29 CFR 1910.177 Servicing multi-piece and single piece rim wheels
• 29 CFR 1910.178 Powered industrial trucks
• 29 CFR 1910.179 Overhead and gantry cranes
• 29 CFR 1910.180 Crawler locomotive and truck cranes
• 29 CFR 1910.181 Derricks
• 29 CFR 1910.183 Helicopters
• 29 CFR 1910.184 Slings

Corrosion (damage mechanism) engineering plays a crucial role in the lifecycle management of material handling equipment by contributing to their design, engineering, inspection, maintenance, repair, and retirement. During the design and engineering phases, an effective corrosion (damage) mechanism review ensures that materials and coatings are selected appropriately to resist environmental and operational conditions that may cause degradation. An effective DMR is essential to extend the useful service life of equipment like powered industrial trucks, overhead cranes, and slings. DMRs help in the development of specifications that mitigate corrosion (damage) risks, thereby enhancing the safety and reliability of these equipment.

For the in-service inspection phase, DMR strategies employ various techniques, such as visual inspections, non-destructive testing (NDT), and advanced diagnostic tools, to assess the condition of material handling equipment. Regular inspections are essential for identifying early signs of corrosion, wear, and fatigue, which are critical for major components like multi-piece rim wheels and gantry cranes that operate under heavy loads and stress. Corrosion engineers interpret the data from these inspections to determine the extent of damage and recommend corrective actions during the damage mechanism review. This proactive approach helps prevent unexpected failures and extends the operational life of the equipment.

DMR-based maintenance and reliability strategies are crucial for maintaining the integrity and performance of material handling equipment. In corrosive environments, such as those involving helicopters or truck cranes, specific maintenance procedures may be recommended to mitigate the effects of marine or industrial atmospheres. This ensures equipment remains functional, safe, and compliant with OSHA regulations, reducing downtime and operational costs.

READ: Insights Report: Improving Human Reliability Across Enterprise Operations with Workforce Excellence

Subpart O Machinery and Machine Guarding
29 CFR 1910 Subpart O, Machinery and Machine Guarding, outlines regulations that may interface with the DMR process.

• 29 CFR 1910.212 General requirements for all machines
• 29 CFR 1910.213 Woodworking machinery requirements
• 29 CFR 1910.215 Abrasive wheel machinery
• 29 CFR 1910.216 Mills and calenders in the rubber and plastics industries
• 29 CFR 1910.217 Mechanical power presses
• 29 CFR 1910.218 Forging machines
• 29 CFR 1910.219 Mechanical power-transmission apparatus

The role of damage (corrosion) mechanism review is crucial in the life cycle assessment of machinery and machine guarding equipment such as woodworking, abrasive wheel, and forging machines. The DMR assessment helps identify, analyze, and mitigate the corrosion-related issues that can potentially impact the performance, safety, and longevity of these machines. Corrosion engineers can assess the types of corrosion that affect these tools, such as moisture-induced rusting, and recommend protective coatings or the use of stainless steel components to enhance durability.

In abrasive wheel machinery, corrosion can weaken grinding wheels and support components, risking failure during operation. Corrosion engineers perform damage mechanism reviews to identify corrosion processes like galvanic or stress corrosion cracking. Exposure to coolant fluids commonly causes metal corrosion, and assessments recommend corrosion-resistant materials or protective coatings for the machinery's metal parts.

Subpart Q Welding, Cutting and Brazing
29 CFR 1910 Subpart Q, Welding, Cutting, and Brazing, outlines regulations that may interface with the DMR process.

• 29 CFR 1910.251 Definitions
• 29 CFR 1910.252 General requirements
• 29 CFR 1910.253 Oxygen-fuel gas welding and cutting
• 29 CFR 1910.254 Arc welding and cutting
• 29 CFR 1910.255 Resistance welding

Welding is a manufacturing process of joining materials, typically metals, by melting their edges and allowing them to fuse. The material properties, such as thermal conductivity, melting point, and chemical composition play a crucial role in determining the welding procedure’s success, and the weld product's quality and integrity. Damage mechanism reviews for weld joints often include identifying mechanism such as thermal distortion, residual stresses, and cracking (such as hot cracking or cold cracking) during the welding manufacturing process. DMRs enable engineers and technicians to mitigate this by carefully controlling the welding parameters and using filler materials with a suitable composition to reduce the cracking tendency.

Damage mechanism reviews for equipment and components fabricated using cutting processes often include identifying issues such as thermal distortion, microstructural changes, and surface oxidation. For instance, cutting stainless steel with a plasma cutting process presents challenges due to its high chromium content, which can create a tough oxide layer on the cut surface, impeding the cutting process and affecting cut quality. By carefully controlling cutting parameters and using inert gases to prevent oxidation, engineers and technicians can improve the efficiency and quality of cuts in stainless steel.

Thus, in welding, cutting, and brazing, material properties and potential damage mechanisms significantly influence the outcomes and longevity of joints and cuts. DMRs help in understanding these factors and applying appropriate engineering solutions, such as selecting suitable filler materials, optimizing process parameters, and using protective measures.

Subpart R Special Industries
29 CFR 1910 Subpart R, Special Industries, outlines regulations that may interface with the DMR process.

• 29 CFR 1910.261 Pulp, paper, and paperboard mills
• 29 CFR 1910.262 Textiles
• 29 CFR 1910.263 Bakery equipment
• 29 CFR 1910.264 Laundry machinery and operations
• 29 CFR 1910.265 Sawmills
• 29 CFR 1910.266 Logging operations
• 29 CFR 1910.268 Telecommunications
• 29 CFR 1910.269 Electric power generation, transmission, and distribution
• 29 CFR 1910.272 Grain handling facilities

The usefulness of damage mechanism reviews extends to special industries covered under federal regulation 29 CFR Subpart R, Sections 1910.261 through 1910.272. For example, in the textile industry, materials used in machinery and equipment must exhibit properties such as wear resistance, thermal stability, and resistance to chemicals like dyes and bleaches. Common damage mechanisms for this equipment include wear and tear, chemical attack, and thermal degradation.

References
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Narang D. Dual Benefits of Damage Mechanism Reviews. In: 2024 Spring Meeting and 20th Global Congress on Process Safety. AiCHE; 2024. Accessed June 2, 2024. https://www.aiche.org/academy/conferences/aiche-spring-meeting-and-global-congress-on-process-safety/2024/proceeding/paper/83c-dual-benefits-damage-mechanism-reviews

Narang D. The Second Benefit of Damage Mechanism Reviews - Damage (corrosion) mechanism reviews in achieving cost effective and efficient implementation of major reliability (asset integrity) best practices. Oil Gas IQ Div IQPC. Published online August 8, 2024. https://www.oilandgasiq.com/process-optimization/articles/the-second-benefit-of-damage-mechanism-reviews

29 CFR 1910 -- Occupational Safety and Health Standards. Accessed August 8, 2024. https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910?toc=1

29 CFR 1910, Subpart L Fire Protection. Accessed December 29, 2023. https://www.ecfr.gov/current/title-29/part-1910/section-1910.119

ArtBreeder.Com - Generative Adversarial Networks are the main technology enabling Artbreeder. Accessed June 6, 2024. https://www.artbreeder.com

Narang D. Engineering Framework to Assess Equipment Reliability of Air Fin Coolers in Process Plant Industries. In: 2024 Spring Meeting and 20th Global Congress on Process Safety. AiCHE; 2024. https://www.aiche.org/academy/conferences/aiche-spring-meeting-and-global-congress-on-process-safety/2024/proceeding/paper/55cm-engineering-framework-assess-equipment-reliability-air-fin-coolers-process-plant-industries

Narang D. Selection and Integration of Risk Based Inspection Tool in Hydrocarbon Facilities. Presented at: American Petroleum Institute Inspection and Mechanical Integrity Summit; February 2, 2017; Galveston, Texas.

Narang D. SECRETS TO BECOMING A WELL-INFORMED RISK BASED INSPECTION (RBI) PROFESSIONAL. Insp J. 2018;24(3). https://inspectioneering.com/journal/2018-06-28/7762/secrets-to-becoming-a-well-informed-risk-based-inspection-profes

29 CFR 1910 Subpart M Compressed Gas and Compressed Air Equipment. Accessed December 29, 2023. https://www.ecfr.gov/current/title-29/part-1910/section-1910.119

29 CFR 1910 Subpart N Materials Handling and Storage. Accessed December 29, 2023. https://www.ecfr.gov/current/title-29/part-1910/section-1910.119

29 CFR 1910 Subpart O Machinery and Machine Guarding. Accessed December 29, 2023. https://www.ecfr.gov/current/title-29/part-1910/section-1910.119

29 CFR 1910 Subpart Q Welding, Cutting and Brazing. Accessed December 29, 2023. https://www.ecfr.gov/current/title-29/part-1910/section-1910.119

OSHA Fact Sheet, Controlling Hazardous Fume and Gases During Welding. Accessed January 23, 2024. https://www.osha.gov/sites/default/files/publications/OSHA_FS-3647_Welding.pdf

29 CFR 1910 Subpart R Special Industries. Accessed December 29, 2023. https://www.ecfr.gov/current/title-29/part-1910/section-1910.119