Asset Integrity Silos Are a Process Safety Problem, and Subcontractors Are Exposed
According to Inspectioneering Journal, asset integrity programs at refineries, chemical plants, and other Process Safety Management-regulated facilities often operate in isolation from the broader PSM framework, creating gaps that carry real compliance and liability consequences for everyone on site, including subcontractors. The publication spoke with Ken Min, Executive Director of Asset Integrity Services at MISTRAS Group, about why that silo problem persists and what a more integrated approach looks like in practice.
Background
Process Safety Management, the OSHA standard codified under 29 CFR 1910.119, contains 14 elements. Mechanical integrity, the element that governs inspection, testing, and maintenance of pressure vessels, piping, relief systems, and other critical equipment, is widely considered one of the most resource-intensive of those 14 to manage. It is also, according to Min, one of the most likely to get treated as a standalone program rather than as part of a connected system.
Min brings a perspective shaped by time on both sides of the fence. He spent the first half of his career as an owner-operator, doing hands-on inspection work including internal inspections inside towers and vessels, and the latter half in consulting roles across oil and gas, chemical, pharmaceutical, and ammonia refrigeration facilities. That crossover experience is relatively rare, and it gives him a useful lens on why programs succeed or struggle.
His observation, reported by Inspectioneering, is that program maturity does not correlate neatly with facility size or industry sector. Refineries and large chemical plants tend to have more developed asset integrity programs, but the biggest driver of program quality turns out to be culture and leadership support. A well-resourced program with weak leadership buy-in will underperform a leaner program where management treats mechanical integrity as a genuine priority.
Analysis
The silo problem Min describes is not new, but it remains stubbornly common. Asset integrity teams track inspection intervals, corrosion rates, and fitness-for-service assessments. Process safety teams manage hazard analyses, management of change procedures, and incident investigations. In many facilities, these groups do not talk to each other systematically, which means a change flagged in a HAZOP may never prompt a re-evaluation of inspection frequency, or an inspection finding that should trigger a management of change review gets closed out within the mechanical integrity system and goes no further.
For subcontractors, this disconnect creates several concrete problems.
First, scope gaps. When asset integrity and process safety are not aligned, the work orders and inspection scopes subcontractors receive may not reflect the full risk picture. An inspection contractor brought in to perform a scheduled thickness measurement survey may not be aware of a recent process change that altered corrosion mechanisms. That contractor completes the work as scoped, the data looks acceptable against historical baselines, and neither party realizes the baseline is no longer valid.
Second, OSHA exposure. Under PSM, owner-operators have a duty to ensure that contractors performing work in covered processes understand the hazards associated with that work. That duty is shared. Contractors are required to train their workers, maintain safety records, and advise the operator of hazards they identify. When the operator’s own programs are siloed, the information flow that PSM requires breaks down, and both parties are exposed if OSHA comes looking after an incident.
Third, cost. Redundant or misaligned inspection programs cost money. Facilities that run asset integrity and process safety as separate administrative systems often end up with duplicated documentation, inconsistent equipment histories, and re-inspection work driven by records problems rather than actual equipment condition. Subcontractors absorb some of that inefficiency in the form of unclear work scopes, change orders, and disputes over what was actually required.
The broader implication of Min’s framing is that treating mechanical integrity as a PSM element rather than a standalone compliance checkbox changes what subcontractors are expected to deliver. It shifts the ask from “complete the inspection” to “contribute to a risk management system.” That is a meaningful difference in how field work gets scoped, documented, and evaluated.
What It Means for Subcontractors
- If you work in PSM-covered facilities, understand that OSHA holds both the operator and the contractor responsible for information sharing. Document what you communicate about identified hazards, not just the inspection results themselves.
- Scope gaps are a two-way risk. If you’re handed an inspection scope that doesn’t reflect recent process changes, ask questions before you start. A single conversation with the facility’s mechanical integrity team can prevent a re-work dispute later.
- Culture and leadership matter when qualifying customers. Min’s point about leadership support driving program maturity is worth factoring into how you evaluate owner-operators as clients. Facilities with weak safety culture create disproportionate compliance risk for their contractors.
- Integrated PSM programs generally produce better-defined work scopes, cleaner equipment histories, and fewer change orders. They also tend to be more demanding on documentation standards. Know what you’re walking into before you bid.
- MISTRAS Group operates at the intersection of inspection services and PSM consulting. Their positioning reflects a broader market trend toward integrated integrity services. Subcontractors who can speak fluently to both inspection execution and PSM context are increasingly differentiated in this market.
