A 12-Step FEMI Incident Investigation Framework Every Pressure Equipment Operator Should Know
According to Inspectioneering Journal, a framework for investigating fixed equipment mechanical integrity (FEMI) incidents, covering everything from minor near-misses to major hazardous fluid releases, was outlined in the September/October 2025 issue by John Reynolds, Senior Editor at Inspectioneering and Principal Consultant at Intertek.
Why FEMI Incidents Demand a Structured Response
Reynolds describes a 12-step work process designed to help operating sites learn from FEMI incidents of any magnitude. The process, which Reynolds calls a “learning from incidents” (LFI) framework, is intended to be applied whenever a FEMI event occurs, a problem is noticed that could have caused a release of hazardous fluids, a near-miss takes place without an actual release, or something improper or unexpected is discovered on pressure equipment.
The framework is grounded in existing industry guidance, including API RP 585, the American Petroleum Institute’s recommended practice specifically covering pressure equipment integrity incident investigation. OSHA’s Process Safety Management standard (29 CFR 1910.119) and the concept of Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) also form part of the regulatory backdrop for this type of investigation work.
The core argument is that sites need to act quickly and systematically when a FEMI problem surfaces, and that a repeatable investigation process is the most reliable way to prevent recurrence.
What It Means for Subcontractors
- If you perform inspection, maintenance, or repair work on pressure equipment, a FEMI incident at a facility where you worked can draw scrutiny of your scope. Having your own documented investigation process demonstrates due diligence.
- Familiarity with API RP 585 is increasingly expected on process safety-regulated sites. Subcontractors working in refineries, petrochemical plants, or upstream processing facilities should review this recommended practice.
- Near-misses matter as much as actual incidents. Reynolds’ framework applies to discoveries of improper conditions, not just releases, meaning your crew’s reporting habits are part of your liability exposure.
- RAGAGEP compliance is an OSHA requirement under PSM (29 CFR 1910.119). Subcontractors operating on PSM-covered sites should be able to show their work aligns with recognized engineering practices, not just site-specific instructions.
