Preventing Chemical

Accidents
Mechanical Integrity
Preventing Maintenance Breakdowns

Process Safety Management Training

from the
NJ Work Environment Council

This material was produced under grant SH-17813-08-60-F-34 from the Occupational Safety and
Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or
policies of the U.S. Department of Labor, nor does mention of trade names, commercial products,
or organizations imply endorsement by the U.S. Government. This curriculum is revised from
materials originally developed by the United Steelworkers Tony Mazzocchi Center for Safety,
Health, and Environmental Education and produced by the Steelworkers Charitable and
Educational Organization, funded in whole or in part with funds from the Occupational Safety and
Health Administration, U.S. Department of Labor (grant number SH-16632-07-60-F-42).

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Table of Contents
About WEC iii
Preventing Chemical Accidents iv
The Small Group Activity Method v
The Factsheet Reading Method vii

Mechanical Integrity -
Preventing Maintenance Breakdowns 1

Task 1 2
Task 2 13

Evaluation 25

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

About WEC
The New Jersey Work Environment Council (WEC) is a non-profit
collaboration of organizations working for safe, secure jobs, and a
healthy, sustainable environment.

Visit WECs website at www.njwec.org

For more information about WECs programs and services,

contact:
Rick Engler, Director
New Jersey Work Environment Council
142 West State Street - Third Floor, Trenton, NJ 08608-1102
Telephone: (609) 695-7100
Fax: (609) 695-4200
E-mail: [email protected]

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Preventing Chemical Accidents

Unexpected releases of highly hazardous toxic, reactive, or
flammable chemicals create the possibility of a disaster for
workers, employers, and communities.

OSHAs Process Safety Management Standard helps prevent

accidental releases of highly hazardous chemicals, thus protecting
employees, as well as plant neighbors.

Effective worker training about PSM helps achieve safer,

healthier, and more productive workplaces.

In New Jersey, PSM regulates approximately 100 facilities,

including certain chemical plants, oil refineries, food processors,
electric utilities, warehouses, and public and private sector water
and sewage treatment operations. PSM may also cover other
types of facilities. PSM has special provisions for contractors
working in covered facilities.

WECs training curriculum covers key aspects of the PSM

standard. Training introduces the concept of systems of safety
and accident prevention and why facilities should establish an
organizational structure to oversee PSM implementation. We
address OSHAs performance-based requirements for a plant
mechanical integrity program. Training also covers accident,
incident, and near-miss investigations, focusing on root causes.
We also can provide training on closely related subjects, such as
the New Jersey Toxic Catastrophe Prevention Act (TCPA), employer
and worker/union rights to participate during OSHA and TCPA
inspections, and development of effective labor-management
safety and health committees.

For more information, contact:

Denise Patel, PSM Outreach Coordinator
WEC, 142 West State St, Third Floor
Trenton, NJ 08608

Or call: (609) 695-7100, Extension 305

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Fax: (609) 695-7100

E-Mail: [email protected]

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

The Small Group Activity Method

Basic Structure
The Small Group Activity Method* is based on a series of problem-
solving activities. An activity can take from 45 minutes to an hour.
Each activity has a common basic structure:

Small Group Tasks

Report-Back
Summary

1. Small Group Tasks: The training always begins with groups

working together at their tables. Each activity has a task, or set of
tasks, for the groups to work on. The task asks that the groups
use their experience and the factsheets to solve problems and
make judgements on key issues.

2. Report-Back: For each task, the group selects a scribe that

takes notes on the small group discussion and reports back to the
class as a whole. During the report-back, the scribe informs the
entire class as to how his or her group solved the particular
problem. The trainer records each scribes report-back on large
pads of paper in front of the class so that everyone can refer to
them.

3. Summary: Before the discussion drifts too far, the trainer

needs to bring it all together during the summary. Here, the
trainer highlights the key points of the activity and brings up any
problems or points that may have been overlooked during the
report-back.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

*The Small Group Activity Method (SGAM) is based on a training procedure developed by
Englands Trades Union Congress (TUC) in the 1970s. The Labor Institute and Oil, Chemical,
and Atomic Workers Union (now part of the United Steelworkers Union) used a similar
method around economic and health and safety issues for workers and further developed
the procedure into SGAM. The New Jersey Work Environment Council has used SGAM since
1986.

Three Basic Learning Exchanges

The Small Group Activity Method (SGAM) is based on the idea that
every training is a place where learning is shared. With SGAM,
learning is not a one-way street that runs from trainer to worker.
Rather SGAM is a structured procedure that allows us to share
information. It is based on three learning exchanges:

Worker-to-Worker
Worker-to-Trainer
Trainer-to-Worker

Worker-to-Worker: Most of us learn best from each other. SGAM

is set up in such a way as to make the worker-to-worker exchange
a key element of the training. The worker-to-worker exchange
allows participants to learn from each other by solving problems
in their small groups.

Worker-to-Trainer: Lecture-style training assumes that the

trainer knows all the answers. With SGAM it is understood that the
trainers also have a lot to learn and this is the purpose of the
worker-to-trainer exchange. It occurs during the report-back and it
is designed to give the trainer an opportunity to learn from the
participants.

Trainer-to-Worker: This is the trainers opportunity to clear up

any confusion and make points they think are key. By waiting until
the summary section, trainers know better what people need to
know.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

The Factsheet Reading Method

The process described below focuses everyone on the important
information in the factsheets.

The process is as follows:

First, select a scribe for this Task.

Each of you will be assigned a small number of factsheets to read.

You will then share the factsheet information with your table.

Your trainer will assign your individual factsheets this way:

Starting with the scribe and moving to the left, count out loud
from 1 to 8. Keep going around the table until all numbers
(factsheets) are distributed. For example, if there are four people
at your table, the scribe will have self-assigned Factsheets 1 and
5; the person to their left will have Factsheets 2 and 6, etc. The
assigned numbers correspond to Factsheets 1 through 8 on the
following pages.

Once everyone has read their assigned factsheets individually,

your scribe will go around the table and ask each of you to explain
to the group what you have learned. You do not need to take
notes. Factsheets should be explained in the order assigned (1
through 8), since the factsheets build on the previous one. In this
way, we all start at the same place and with the same
information.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Mechanical Integrity -
Preventing Maintenance Breakdowns

Purposes

To become familiar with the OSHA performance-based

requirements for a plant mechanical integrity program.

To examine the causes and solutions of breakdown

maintenance.

This Activity has two tasks.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Task 1

In your groups, choose a scribe. Then, using factsheets 1

- 6 on pages 3 - 11, answer the following questions:

1. What are some causes of maintenance breakdowns?

2. Could maintenance breakdowns happen at your plant?

List some examples.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Factsheet #1
Maintenance Myths Most Often Heard

Here are some commonly-used excuses for not following safe

mechanical integrity practices and examples of the consequences
of not doing so:

Its only temporary:

A leak developed on one of the six in-line reactors. All six were
connected with 28-inch-diameter pipes and expansion bellows.
The leaking reactor was bypassed with a 20-inch pipe with two
elbows and the expansion bellows were left intact.

The pipe was not supported properly; it was resting on

scaffolding. Because of the bellows, it was free to rotate or
squirm and in the process it failed, killing 28 people and
destroying the plant.

Its factory set; no need to test it:

In an automatic fire-fighting system, a small explosive charge cut
a rupture disc and released the fire-fighting agent, Halon. The
manufacturer said it was not necessary to test. To test would
require the loss of the Halon which was very expensive.

The buyer insisted on the test even with the added expense. The
smoke detectors worked but when the explosive charge was
activated, the rupture disc was not activated. The manufacturer
was in error.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Factsheet #1 (continued)

Go ahead and use this one; itll work:

A carbon steel valve was painted with aluminum paint instead of
using a stainless steel valve. It corroded rapidly.

I dont need an operator; Im just going to look:

A maintenance foreman was asked to look at a faulty cooling
water pump. He decided that, to prevent damage to the
machine, it was essential to reduce its speed immediately. He did
so, but did not tell any of the operators. The cooling water rate
fell; the process was upset; and a leak developed on a cooler.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Sources: Accident at Amoco Chemicals related by Glenn Erwin, Health and Safety
Coordinator, OCAW (now USW); and Trevor A. Kletz, What Went Wrong? Case Histories of
Process Plant Disasters, Houston: Gulf Coast Publishing Company, Second Edition,
November 1989.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Factsheet #2
Work Order Backlog: #1 Warning Sign

Most companies have very good written preventive maintenance

(PM) plans on equipment. But in reality, as the work orders pile
up, they are unable to keep their PMs caught up.

To make matters worse, preventive maintenance work orders are

often treated as having a lower priority than most other work
orders.

The problem is compounded by the fact that most companies do

not employ enough maintenance workers to stay on top of the
regular work orders, much less the PMs.

A huge backlog of work orders is a sign that the Mechanical

Integrity (MI) program is not doing what it is intended to, and it
may be considered a violation of the performance-based Process
Safety Management (PSM) Standard.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Factsheet #3
If It Aint Broke . . .

Many companies consciously decide to Run to Failure (RTF). RTF

is rarely less costly than preventing failure. A company that
manages using RTF twists the old clich, If it aint broke, dont fix
it. Unfortunately, this approach can lead to catastrophe.

An ounce of prevention is worth a pound of cure is a better

maxim:

A $10 seal may wind up costing thousands of dollars, not to

mention death and injury.

The normal rule of thumb is that corrective (breakdown)

costs are four to five times more expensive than preventive
costs.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Source: Total Productive Maintenance, Marshall Institute, Inc. (2900 Yonkers Road, Raleigh,
NC).

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Factsheet #4
Understaffing Leads to Problems: A Case
Study

During testimony on the PSM Standard, one USW member

described some of the effects that the reduction of maintenance
workers had at his plant.

Maintenance staff cut in half:

The staffing of the Mobil Beaumont refinery has steadily

decreased in the past ten years. The Beaumont refinery had over
2,000 hourly employees, of which 1,200 were permanent
maintenance employees when I went to work there 20 years ago.
We now have less than 600 maintenance workers.

The effects dont hit you overnight:

Maintenance workforce reductions are not something that hit you

overnight. The effects are gradual; but as time marches on, the
reductions become more and more obvious.

Running maintenance today in both quality and quantity is much

worse than 1015 years ago. Pumps and compressors are not
maintained. They cannot be properly maintained when the
people are not there to do the work.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Factsheet #4 (continued)

The potential for disaster is present:

Leaks of all sorts: oil, chemicals, which include toluene, ketone,

etc., are not addressed in a timely manner. The limited amount of
maintenance people are kept busy doing work necessary to
maintain production; and the less important problems, in the
companys judgment, are left unattended.

Understaffing leads to excess overtime and fatigue:

Years after this 1991 testimony, the problem of understaffing and

related extended working hours was highlighted by the U.S.
Chemical Safety and Hazard Investigation Board (CSB) in their
2007 Investigation Report of the March 2005, BP refinery
explosion and fire in Texas City. The incident occurred during the
startup of an isomerization (ISOM) unit when a raffinate splitter
tower was overfilled. Among the underlying factors the CSB
identified that resulted in overfilling the tower was ISOM
operators were likely fatigued from working 12-hour shifts for 29
or more consecutive days.

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Preventing Chemical Accidents: Mechanical Integrity Preventing Maintenance Breakdowns

Source: Testimony given before OSHA from USW member Jimmy Herrington, Local 4-243,
February 24, 1991 [Emphasis added]; U.S. Chemical Safety and Hazard Investigation Boards
Investigation Report: Refinery Explosion and Fire, Report No. 2005-04-1-TX, March, 2007.

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 Factsheet #5
Maintenance Downsizing

The number of production and maintenance workers in the

petrochemical industry has been dropping since 1989.

But, along with these workforce reductions came an increase in

production.

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Sources: U.S. Department of Labor, Handbook of Employment and Earnings U.S. Labor
Statistics, ninth edition, Lanham, MD: Bernan Press, March 2008; and U.S. Census Bureau,
Statistical Abstract of the United States: 2006.

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Factsheet #5 (continued)

A 30-year study of accidents in the petrochemical industry

revealed that incidents which resulted in large property damage
losses were most often caused by mechanical failure in the
process equipment (41 percent
of the time). The most recent update of this study shows piping
failures and leaks, cryogenic plant equipment failure, and weather
conditions as major causes.

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Sources: U.S. Department of Commerce, Survey of Current Business, June issues; Garrison,
W. E., PE, Large Property Damage Losses in the Hydrocarbon-Chemical Industries: A Thirty-
Year Review, Twelfth Edition, Chicago: Marsh and McLennan Protection Consultants; and The
100 Largest Losses: 1972-2001, Twentieth Edition, 2003.
Factsheet #6
Longer Time between Turnarounds Leads to
Danger

Prior to the 1970s, the average length of time between

turnarounds was one year. Now this period is much greater, with
the duration between turnarounds sometimes as long as five
years. This longer length of time means that some equipment,
which can only be repaired when the unit is shutdown, has to
wait.

A typical result of long turnaround times is that process units are

run under dangerous conditions that would not have been
acceptable years ago. A true life example is told in the
calculated risks story below:

The Calculated Risks:

A[n] . . . example of calculated risks occurred prior to a

scheduled turnaround on the FCC. This fluid catalytic
cracking unit had turnarounds put off time and again,
because corporate needed it to meet gasoline demands.
The expansion joint . . . was found to have a hole in it. The
company dealt with this by installing a camera on the
expansion joint so the operator could monitor the hole. The
unit should have been shut down. It would have been shut
down ten years ago; however, a decision was made to
continue running the unit despite the potential of very
radical consequences.

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Source: USW member Jimmy Herrington, Local 4-243, testimony before OSHA, February 24,
1991.

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17
Task 2

Scenario:

During the night shift on unit A at ChemPetro, the process

operator, Debbie, noticed a severe vibration on E-101 G fan.
She radioed the control room and asked the Board Operator, Jim,
to write a work order to get the bearings replaced.

Jim filled out the work order and gave it to his Foreman, Bob.

Bob made a notation in the unit log book that the bearings were
bad and forwarded the work order to the unit supervisor for
approval. Bob and his crew were finishing up their night rotation
and were starting their days off.

When Ernest, the Unit Supervisor, arrived on the day shift, he

assigned it a priority 2 (complete within a week) because it was
cool outside and he knew they could run without it. Besides, the
maintenance crew was already busy repairing the centrifuge
which was a priority 1 (overtime authorized).

At 3:00 a.m. on the following day, the bearing failed on E-101 G

creating such a vibration that a pressure gauge leaked, causing a
fire.

During the investigation that followed, it was found the vibration

switch had failed to trip the fan off the line. It had been wired
wrong, probably since the time of installation.

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Task 2 (continued)

In your groups, choose a scribe. Then, using factsheets 1

- 6 on pages 14 - 21, answer the following questions:

1. List ways this fire could have been prevented.

2. In your groups, develop a preventive maintenance

program for ChemPetro. List the key elements of the
program below.

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 Factsheet #1
The PSM Standard Is Performance-based
A Review from the Introduction to PSM
Activity

Performance-based Standards

The Process Safety Management (PSM) Standard is a

performance-based standard. That means it is goal-oriented and
what you should judge is a programs effectiveness. The exact
specifications are not spelled out, just the desired results.

The PSM Standard gives each facility the flexibility to design its
own program to match its needs, as long as the outcome prevents
or minimizes major releases, spills, fires, and explosions.
(Specification-based OSHA standards prescribe precise rules, such
as a guardrails height, exact limits of exposure, etc.)

Your work experience is your guide.

Another way to understand the accident prevention requirement

of a performance standard is to think in terms of our five senses.
We can look and listen for hazards; we can feel for vibrations and
smell for leaks (although that is not always trustworthy); and, at
times, we may even be alerted by our sense of taste. However,
the most important sense we bring to the job is our work
experience.

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Factsheet #1 (continued)

You should ask yourself the following question when

reviewing your facilitys PSM program:

Will this program, as it is written and applied, help to prevent

accidents? If the answer is no, then the company is not
complying with the spirit and intent of the law.

For example, if the company develops a preventive

maintenance program (PM) but assigns PM work orders low
priority, your work experience tells you that there really is no
PM program!

Remember, this is a performance-based standard. It does not

spell out the specifics, just the desired results. The goal or
desired results of the Mechanical Integrity (MI) element of the
PSM Standard is designed to prevent accidents through the proper
maintenance of equipment. Common sense and experience are
important tools to determine whether or not an MI system is
fulfilling the intent of the PSM Standard.

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 Factsheet #2
What the PSM Standard Covers

The requirements for mechanical integrity under the PSM

Standard apply to six specific types of process equipment where
failure is likely to be catastrophic.

These types of equipment, used in the handling of highly

hazardous chemicals are:

1. Pressure vessels and storage tanks;

2. Piping systems (including valves and other components);

3. Relief and vent systems and devices;

4. Emergency shutdown systems;

5. Controls (monitoring devices and sensors, alarms and

interlocks); and

6. Pumps.

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Source: OSHA Process Safety Management Standard 29 CFR 1910.119, 57 FR 6406,
February 24, 1992.

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 Factsheet #3
OSHAs Elements for an MI Program

According to OSHA, the necessary elements of a good mechanical

integrity (MI) program are:

Establish and implement written procedures to maintain the

integrity of process equipment.

Train employees and contractors involved in maintaining the

integrity of equipment.

Perform periodic inspection and testing, following

recognized and generally accepted good engineering
practices, and document that inspections have been done.

Correct equipment deficiencies before further use or in a

safe and timely manner.

Develop a quality assurance program to ensure that:

o Equipment for new plants is suitable for use in the

process, and is properly installed; and
o All maintenance materials, spare parts and equipment
are suitable for intended use.

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Source: OSHA Process Safety Management Standard, 29 CFR 1910.119, 57 FR 6356,
February 24, 1992.
Factsheet #4
Why Preventive Maintenance?

Its the Law!

OSHA: The PSM standard requires preventive maintenance be

performed before further use of the equipment or in a safe and
timely manner when necessary means are taken to assure safe
operation.

EPA: The Environmental Protection Agency has rules to cover

preventive maintenance programs within its Risk Management
Plan requirements.

NJ TCPA: In addition to the OSHA PSM & EPA requirements, the NJ

Department of Environmental Protection, under the NJ Toxic
Catastrophe Prevention Act (TCPA), requires preventive
maintenance be performed within 3 months or a written
justification must be provided including an explanation of the
necessary measures taken to ensure safe operation.

TCPA also requires companies to maintain accurate records of all

inspections, breakdowns, repairs and replacements of process
equipment. All mechanical integrity/preventive maintenance
records must be kept for the lifetime of the process equipment.

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Factsheet #4 (continued)

If You Dont, It Costs $$$.

The BP Texas City refinery explosion and fire in March 2005, is a

painful example of the cost of failing to perform preventive
maintenance. This disaster happened in part because several
instruments were out of service and the operators had no way of
knowing that a critical unit was being overfilled with highly
flammable liquids. Timely and proper maintenance might have
saved the lives of 15 workers and prevented another 180 from
being injured. It also might have saved BP from financial losses
that have thus far totaled over $1.5 billion.

It Pays.

According to some corporate managers, there can be positive

benefits from Process Safety Management:

Process safety management is intended to help you

recognize, understand and control all your process hazards.
If you do that, youre going to understand and control your
business; it runs better
. . . its more efficient and your qualitys higher.

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Sources: Federal Register, Vol. 58, No. 201, October 20, 1993; Consolidated Rule Document
2009, Toxic Catastrophe Prevention Act; Ray Brandes, retired director of safety for ICI
Americas; and U.S. Chemical Safety and Hazard Investigation Board Investigation Report:
Refinery Explosion and Fire, Report No. 2005-04-1-TX, March 2007.

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 Factsheet #5
Not All Employees Receive the Same Safety
Training

After the Phillips 66 Houston Chemical Complex explosion in 1989,

which killed 23 workers and injured 232 others, OSHA
commissioned a team of experts to study the use of contractor
labor in the petrochemical industry. One of the main concerns of
the study (called the John Gray Report) was to determine the
quality of health and safety training that contract workers
received.

The survey showed that only 62 percent of contract workers

reported that they received nine or more hours of company
training in the last year, whereas 81 percent of the direct hires
reported nine or more hours of training.

The report concluded:

. . . the quality of the labor force in this industry is declining

and the number of employees who are associated with higher
accident rates (younger, less tenure, less education) is
increasing. One implication of this is obvious: The need for
increased education and training investments in this
workforce is substantial.

Different companies provide different types of training, but its not

always enough.

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Source: John Gray Institute, Managing Workplace Safety and Health: The Case of Contract
Labor in the U.S. Petrochemical Industry, Lamar University System, July 1991, p. 77.

Factsheet #6
Maintenance Failures Can Have Terrible
Results

This list illustrates just a few examples of the human cost to both
workers and the community caused by failure to properly
maintain process equipment.

Piping: (Internal Corrosion of Overhead Piping)

May 5, 1988 An explosion and fire at a Shell Oil Refinery in
Norco, Louisiana, killed seven OCAW Local 4-750 workers and
injured 22 others. Some 2,500 residents had to be evacuated
from nearby areas.

Vessel Failure: (Reactor)

August 1992 Three workers were injured and a group of
motorists suffered respiratory injuries from ammonia inhalation
when an explosion ripped through the Arcadian Chemical
Corporation in Lake Charles, Louisiana.

Equipment Failure: (Air Fin Exchanger)

October 1992 An explosion at the Texaco Refinery in
Wilmington, California, injured 16 workers and required the
evacuation of residents within a one-mile area when an air fin
exchanger failed due to unmonitored corrosion.

Wrong Piping: (Feed line elbow)

August 2, 1993 A fire at a Baton Rouge, Louisiana, refinery
occurred when an elbow made of carbon steel instead of the
required chrome alloy steel ruptured. Damage was estimated at
$48 million.

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Overfilled vessel: (Blowdown drum)
March 2005 A blast at the BP Texas City refinery which killed 15
and injured 180 people followed budget cuts of 25 percent from
1998 to 2000 at the plant. A blowdown drum overfilled and
alarms and gauges that were supposed to warn of the problem
did not work properly.

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Summary: Mechanical Integrity
1. Preventive maintenance programs should be established,
funded and staffed to sufficient levels to avoid the need for
breakdown maintenance.

2. Turnarounds need to be held often enough to avoid

breakdown maintenance. Units need to stay down until
scheduled repairs are completed.

3. All maintenance work should be performed by trained and

experienced
crafts workers.

4. Requirements for, and documentation of, contractor training

should be equivalent to that of regular employees.

5. All maintenance work must be done using proper equipment,

installation procedures, safety devices and according to
applicable codes and standards.

6. It is critical to actually implement the written mechanical

integrity program. NJ TCPA requires preventive maintenance
be performed within 3 months and detailed records of
maintenance and inspections be kept for the life of the
equipment.

7. If your workplace frequently experiences breakdown

maintenance, your mechanical integrity program is not
working.

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32
 Preventing Chemical Accidents
Process Safety Management Training from the NJ Work Environment
Council
PROGRAM EVALUATION FORM

Mechanical Integrity Preventing Maintenance Breakdowns

Location:
Date:
Trainers:

CODE: A=EXCELLENT, B= GOOD, C = FAIR, D = POOR, E = N/A

How were the following objectives met? A B

C D E
1. Upon completion of this program, participants will be able to:

To become familiar with the OSHA performance-based

requirements for a plant mechanical integrity program.

To examine the causes and solutions of breakdown

maintenance.

2. Did the tasks address the purposes of the activity?

3. Please evaluate the speaker:

Knowledge of subject

Presentation orderly and understandable

Effective use of teaching tools

(small groups, explanation, assignments)

4. What did you like the most about this activity?

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 More on back.

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5. How could this activity be improved?

Additional Comments:

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