OSHA requires that process equipment and materials meet applicable design specifications before installation. The QA element of MI addresses receiving inspection, material traceability, mill certifications, and the controls needed to ensure that a replacement valve, fitting, or gasket installed in a covered process matches the specification it was supposed to replace. Counterfeit or substandard materials in process piping have caused serious incidents. These letters address what the QA program must include, the role of receiving inspection, and how to handle materials purchased outside normal procurement channels.

What OSHA Has Said

Feb 4, 2013
QA Requirements for Purchased Replacement Parts
OSHA addresses the QA obligations for replacement parts procured for MI purposes. Mill certifications, material test reports, and specification verification are required before installation in a covered process, not as optional good practice.
Read OSHA Letter ↗
Mar 5, 1998
Material Traceability and Mill Certification Requirements
OSHA clarifies that the QA program must ensure material traceability from the point of manufacture to installation. Materials without verifiable provenance require additional verification before use in covered processes.
Read OSHA Letter ↗
Feb 1, 2010
Emergency Procurement and QA and Non-Routine Sourcing
OSHA addresses the scenario where replacement parts are obtained through emergency or non-standard channels. Even in emergency situations, the employer must verify that materials meet specifications before installation.
Read OSHA Letter ↗

⚡ Key Compliance Takeaway

Receiving inspection is not optional. Every replacement part for a covered process needs specification verification and documentation before installation including emergency procurements. Trusting the supplier is not a QA program; verifying the mill cert and checking the marking is.