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PIP ADG008 Specification for Processing Inquiries and Interpretations

PURPOSE AND USE OF PROCESS INDUSTRY PRACTICES In an effort to minimize the cost of process industry facilities, this Practice has been prepared from the technical requirements in the existing standards of major industrial users, contractors, or standards organizations. By harmonizing these technical requirements into a single set of Practices, administrative, application, and engineering costs to both the purchaser and the manufacturer should be reduced. While this Practice is expected to incorporate the majority of requirements of most users, individual applications may involve requirements that will be appended to and take precedence over this Practice. Determinations concerning fitness for purpose and particular matters or application of the Practice to particular project or engineering situations should not be made solely on information contained in these materials. The use of trade names from time to time should not be viewed as an expression of preference but rather recognized as normal usage in the trade. Other brands having the same specifications are equally correct and may be substituted for those named. All Practices or guidelines are intended to be consistent with applicable laws and regulations including OSHA requirements. To the extent these Practices or guidelines should conflict with OSHA or other applicable laws or regulations, such laws or regulations must be followed. Consult an appropriate professional before applying or acting on any material contained in or suggested by the Practice. This Practice is subject to revision at any time by the responsible Function Team and will be reviewed every 5 years. This Practice will be revised, reaffirmed, or withdrawn. Information on whether this Practice has been revised may be found at www.pip.org.

Process Industry Practices (PIP), Construction Industry Institute, The University of Texas at Austin, 3925 West Braker Lane (R4500), Austin, Texas 78759. PIP member companies and subscribers may copy this Practice for their internal use. Changes, overlays, addenda, or modifications of any kind are not permitted within any PIP Practice without the express written authorization of PIP.

PIP will not consider requests for interpretations (inquiries) for this Practice.
PRINTING HISTORY March 2001 May 2002 Issued Technical Revision

Not printed with State funds

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PIP ADG008 Specification for Processing Inquiries and Interpretations

Table of Contents 1. Introduction .................................. 2
1.1 Purpose ............................................. 2 1.2 Scope................................................. 2

6. Inquiry-Handling Process ........... 7 7. Specific Procedures of Function Teams.......................... 9 Appendix A

Inquiry Notices for Practices and Web Page ........................................A-1

2. References.................................... 2
2.1 Process Industry Practices................ 2

3. Definitions .................................... 2 4. PIP Policy for Accepting Inquiries ...................................... 2 5. Requirements ............................... 3
5.1 5.2 5.3 5.4 Responsibilities.................................. 3 Inquiry Identification System.............. 5 Web Page .......................................... 6 Adding Inquiry Instructions to Practices ............................................ 6 5.5 Form Letters ...................................... 6 5.6 Examples of Inquiries ........................ 7

Appendix B
Form Letters Sent by PIP .......................B-1

Appendix C
Example Inquiries with Interpretations .. C-1

Appendix D
Specific Function Team Inquiry Procedures ............................................ D-1

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1.

Introduction
1.1 Purpose This Practice defines how inquiries concerning published PIP Practices are formatted and submitted by an inquirer and describes how inquiries are administered by Process Industry Practices (PIP). Inquirers and other users benefit from responses and interpretations provided by technical specialists participating in PIP. PIP benefits from information that may improve the clarity, technical accuracy, and completeness of the Practices. 1.2 Scope This Practice defines the PIP procedures for submission of inquiries, review of inquiries, and response to inquirers.

2.

References
2.1 Process Industry Practices (PIP) PIP ADG006 Specification for the Revision of PIP Practices

3.

Definitions
For the purpose of this Practice, the following definitions apply: inquirer: Anyone who submits an inquiry to PIP inquiry: A written request to PIP for an interpretation of a specific requirement within a published Practice. An inquiry is not a suggestion to revise a published Practice. Comment: PIP does not treat suggestions for revisions as inquiries. PIP ADG006 contains information pertaining to revisions of published Practices. interpretation: A written response from PIP to an inquiry that clarifies the meaning of a requirement within a published Practice

4.

PIP Policy for Accepting Inquiries

4.1 PIP endorses the concept of users' submitting written inquiries as specific questions on the technical content of Practices to be answered as published interpretations by the applicable Function Team (FT). However, PIP shall not provide the following: Interpretations generated by PIP member(s) without adequate review by a group of FT members Free consultation on specific projects The rationale behind the specific requirements, guidelines, recommendations, etc., contained in the Practices

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4.2 4.3 4.4 4.5

Quick responses to meet the inquirers project schedule or other schedule needs Responses that comment on patented or proprietary designs and equipment Responses that could be construed to give commercial advantage to one or more manufacturers

An interpretation shall state the requirements of the Practice without providing significant additional engineering or guidance to the inquirer. An interpretation shall not describe what the Practice should have stated or will state in a future revision. An interpretation shall not state anything that is technically incorrect. All PIP FTs are required to adopt a specific procedure to handle inquiries if inquiries will be accepted. See Section 7.

5.

Requirements
5.1 Responsibilities 5.1.1 Inquirers Inquirers are expected to follow these procedures: 5.1.2 Prepare written inquiries in accordance with Appendix A. Submit inquiries by letter, fax, or e-mail to the PIP office. If necessary, appeal interpretations to PIP by following the same procedures applicable to a new inquiry.

PIP Office The PIP office shall perform the following: Receive, number, and log inquiries. Maintain a database of all inquiries that captures the inquiry number, inquirers company name, date inquiry is received, and status of the inquiry (i.e., received, forwarded to FT, approved by FT, forwarded to Legal, reviewed by Legal, or issued), such that the database can be sorted by year, company name, FT status, Practice number, and assigned inquiry number. Post the database of inquiries on the PIP website for team leaders to run reports as needed. Acknowledge inquiries when received. Comment: If an inquiry is not in compliance with the requirements of this Practice, the PIP office may return it to the inquirer, using a form letter from Appendix B for this purpose. Maintain copies of the inquiries. Distribute inquiries to the appropriate FTs.

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5.1.3

Obtain PIP Legal review of interpretations prepared by FTs. Distribute approved interpretations to the inquirers or use form letters from Appendix B as directed by FTs. Maintain the PIP Inquiry Web Page in accordance with Appendix A. Publish inquiries and interpretations on the PIP website within 1 month of their distribution to the inquirers. Maintain files of original inquiries and approved interpretations.

Function Team Leaders The FTLs shall perform the following: Assure that Inquiry Response Teams are maintained according to their teams Specific FT Inquiry Procedures as provided in Appendix D. If a Practice is jointly authored by two or more FTs, the FT that has primary responsibility for the Practice shall collaborate with the other teams in reviews and decisions regarding inquiries relevant to their disciplines. Nonmembers and subscribers of PIP shall be excluded from any discussions and decisions related to inquiries. Designate the Inquiry Response Team Leaders who will receive inquiries from the PIP office, develop draft interpretations, and transmit approved interpretations to the PIP office. Comment: FTs should choose the individual(s) assigned to their Inquiry Response Team. Review inquiries and interpretations for consistency and compliance with the requirements of this document. Assure that inquiries and interpretations are provided to all FT members as part of their teams regular meeting minutes, regardless of whether or not the inquiries were discussed in the team meetings.

5.1.4

Inquiry Response Team Leaders The Inquiry Response Team Leader shall perform the following: Assign suffix character(s) and titles as required, track active inquiries, develop draft interpretations, and expedite the resolution of review comments. Comment: Inquiries should normally be resolved in 3 months or less. eRoom may be used to ballot the inquiries. Issue inquiry/response to PIP office.

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If an inquiry is referred for further study, instruct the PIP office to notify the inquirer using Form F in Appendix B. The initial inquiry shall be amended accordingly and reissued after the FT resolves the questions raised in the inquiry. If revision of a Practice is required, the amended response to the inquiry shall be transmitted to the PIP office after the Practice is revised. Propose Practice changes to FT if recommended by Inquiry Response Team.

5.1.5

Inquiry Response Teams Inquiry Response Teams shall perform the following: Review, provide comments, or approve draft responses to inquiries in accordance with the Specific Inquiry FT Procedures shown in Appendix D. Inquiries may be modified by the Inquiry Response Team to permit a Yes or No response. Possible responses are (1) an answer to the question or (2) one of the form letters in Appendix B. Identify issues that may require changes to the Practices as a result of the inquiry.

5.2

Inquiry Identification System The PIP office shall assign a unique identification number to each inquiry upon its receipt. This number shall be shown on the first page of the inquiry. This number shall be used for tracking the inquiry. The identification system shall be as follows: PIP Practice number-I-yy/nns; Title I Yy Nn = = = capital I indicates inquiry the year the inquiry is received (e.g., 00, 01, etc.) a sequence number assigned by the PIP staff, beginning with 01 for the first inquiry received that year for the particular FT (e.g., 01, 02, 03, etc.) a suffix of one or more optional characters assigned by the FT upon receipt of the inquiry (e.g., V, E, T, representing vessels, heat exchangers, tanks, respectively) a brief description of the inquiry that indicates its general subject matter. The title is assigned by the FT and is shown on the first page of the inquiry

Title

Example: VECV1001-I-00/04E; Tube Sheet Ligament Restrictions.

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5.3

Web Page The PIP office shall maintain a web page dedicated to inquiries and interpretations. The web page shall be open to the public without access restrictions. The web page shall be linked to/from the PIP home page and shall have the following information and characteristics: Comment: Possible future enhancement is global word searches on the PIP website. Contact information for the PIP office regarding inquiries A note to the reader that suggestions for revisions to Practices should not be submitted as inquiries Examples of properly written inquiries from Appendix C An inquiry form that may be completed and submitted electronically from the web page. See Appendix A for the e-mail form description. A statement indicating that interpretations may be appealed

5.4

Adding Inquiry Instructions to Practices The following statement shall be included in the forewords of Practices for which inquiries will be accepted: PIP will consider requests for interpretations (inquiries) for this Practice. Instructions for preparing inquiries are available on the PIP website at www.pip.org. The following statement shall be included in the forewords of Practices for which inquiries will not be accepted: PIP will not consider requests for interpretations (inquiries) for this Practice. Comment: The above requirements apply to all Practices published after October 1, 2000. Earlier Practices are exempt from the above requirements until these Practices are revised. Practices such as piping material specifications, forms, and stand-alone data sheets are excluded from inquiries.

5.5

Form Letters If applicable, FTs shall respond to inquiries using the form letters shown in Appendix B, described as follows: FORM A: The inquiry is outside the scope of the Practice and/or not in a form that can be answered with a Yes or No. Comment: Use of this form can usually be avoided by simply restating the question while developing the draft response, avoiding a correspondence cycle.

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FORM B: The inquirer is asking for free consultation service. Comment: This form may be appropriate when it appears that the inquirer is not qualified to understand the Practice. FORM C: The inquirer is asking for PIP approval, advice, endorsement, or opinion about a proprietary design, detail, procedure, or piece of equipment. FORM D: The inquiry is not clear. FORM E: The inquirer is asking for the rationale for requirements in a Practice. FORM F: The inquiry requires study. Comment: This form may be used if an inquiry reveals an apparent error in a Practice that requires correction before a technically correct response can be given. The PIP office shall issue the appropriate form letters with information provided by the FTs inserted. Responses using Form Letters E and F shall be published on the website. The other form letters shall be sent to the inquirers only. 5.6 Examples of Inquiries Appendix C provides examples of acceptable inquiries.

6.

Inquiry-Handling Process
The following flowchart illustrates the general work process for handling inquiries. Use of eRoom is encouraged.

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Inquirer:

Draft inquiry; send to PIP office Verify that it is an inquiry; send acknowledgment; assign number; log in; post to Function Team eRoom Log in; assign suffix character and title; develop response and issue to Inquiry Response Team

PIP Office:

Function Team Leader or Inquiry Response Team Leader:

Inquiry Response Team

Accept or comment on draft response Collate ballots; resolve comments Present unresolved comments to Function Team for majority vote; do not use eRoom

Inquiry Response Team Leader:

Inquiry Response Team Leader:

Issue inquiry/response to Function Team; request changes to Practice if required; log out; send to PIP office Obtain Legal review; prepare inquiry question/response; issue to inquirer; update database with suffix; add to website; log out; file

PIP Office:

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7.

Specific Procedures of Function Teams

Refer to Appendix D for the specific procedures developed by each FT for resolving inquiries. Each FTs procedure should include the following: Name of the person responsible for coordinating the responses to inquiries The number of team members responsible for reviewing inquiries Criteria for being elected or appointed to prepare proposed responses and to review the responses A method of routing draft responses and approved responses A procedure for approving interpretations Schedule requirements for distributions, reviews, and approvals of inquiries and interpretations Comment: It is expected that e-mail and eRoom will be used to expedite the process; however, some teams may elect to process inquiries only periodically, perhaps on the basis of volume received. A system for adding suffix characters to the inquiry numbers assigned by the PIP office A process for capturing and resolving suggested revisions to Practices emanating from inquiries A method for tracking the status of inquiries A method for archiving approved responses Comment: For an example, refer to the Vessel FTs procedure shown in Appendix D.

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Appendix A Inquiry Notices for Practices and Web Page

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Inquiries to Practices
Introduction PIP will consider written requests for interpretations (inquiries) of Practices. PIP will provide interpretations in writing after consulting with the appropriate PIP FT. The PIP FTs responsible for maintaining the Practices meet regularly to consider inquiries. Inquiries and interpretations will be published periodically on the PIP website. As a matter of policy, PIP does not approve, certify, rate, or endorse any item, construction, proprietary device, or activity; accordingly, inquiries that require such consideration will be returned. Moreover, PIP does not act as a consultant on specific engineering problems or on the general understanding or application of the Practice. If, on the basis of the inquiry information submitted, the FT decides that the inquirer should seek other assistance, the inquiry will be returned with the recommendation that such assistance be obtained. All inquiries that cannot be understood because of lack of information will be returned. Suggestions for revisions to Practices should not be submitted as inquiries. These suggestions should instead be submitted as written requests to the PIP office to be considered by the appropriate team in due course. Suggestions for revisions should include recommended wording for the revision and information justifying the revision. Inquiry Format An inquiry should provide the following information: Define the purpose of the inquiry. Provide the background and reference information needed for understanding the inquiry (with sketches as necessary). Cite the applicable Practice and the issue date, paragraphs, figures, and tables. State the inquiry as a precise question that is technically and editorially correct, omitting superfluous background information, and posing the question so that the reply may take the form of Yes or No. A question may result in an answer that generates further questions; these may be worded, If the answer to Question 1 is YES, then may . State the proposed reply.

Inquiries shall be limited strictly to requests for interpretations of the Practices. The scope of an inquiry shall be limited to a single subject or to a group of closely related subjects. An inquiry concerning two or more unrelated subjects will be returned. The PIP office may be contacted at 512-232-3041 regarding questions about the format of an inquiry.

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PIP ADG008 Specification for Processing Inquiries and Interpretations

The inquirer shall include his or her name and mailing address. Inquiries should be typed and e-mailed to director@pip.org, faxed to 512-473-2968, or mailed to: Director of PIP Construction Industry Institute-PIP The University of Texas at Austin 3925 West Braker Lane (R4500) Austin, Texas 78759 Preface to Published Inquiries PIP procedures provide for reconsideration of these interpretations when or if additional information is available that the inquirer believes might affect the interpretations. Further, persons aggrieved by these interpretations may appeal in writing to the director of PIP. PIP does not approve, certify, rate, or endorse any item, construction, proprietary device, or activity. E-mail Form Inquiries may be submitted by e-mail using the following form: Company Name / Address (e-mail or location): Date: To: Director of PIP Construction Industry Institute-PIP The University of Texas at Austin 3925 West Braker Lane (R4500) Austin, Texas 78759 Subject: Inquiry on PIP ____________, dated _______. Ladies and Gentlemen: We (I) require your assistance in interpreting a PIP Practice, described as follows: PURPOSE: BACKGROUND: INQUIRY QUESTION(S): PROPOSED INQUIRY REPLY(S): Please respond to me at the above address. Thank you, Name of inquirer and signature

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Appendix B Form Letters Sent by PIP

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FORM A
Question Outside the Scope of the Practice
(date) Inquiry Number: ( ) Mr./Ms. ( ) (company) (address) Dear Mr./Ms. ( ): We have received your inquiry of ( ). Please be advised that Process Industry Practices (PIP) issues interpretations in response to questions concerning the meaning of its Practices and is always ready to consider suggestions for revisions to its Practices. PIP can only respond to questions that are clearly stated concerning subject matter in the Practices and that strictly pertain to the meaning of the Practices. Your inquiry appears to be within the scope of PIP ( ). We suggest that you review this Practice and present the full particulars of whatever requirement you wish to have interpreted. Please resubmit your question so that it poses a specific question about the meaning of a requirement in a Practice. Questions should be composed so that a "Yes" or "No" answer is possible. Should you have suggestions for a revision to a Practice, please submit them with supporting technical information to this office. Very truly yours, ___________________ PIP Director cc: ( ) FT Leader

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FORM B
Technical Consultation Requested
(date) Ref: ( ) Mr./Ms. ( ) (company) (address) Dear Mr./Ms. ( ): We have received your inquiry of ( ). Please be advised that Process Industry Practices (PIP) issues interpretations in response to questions concerning the meaning of its Practices and is always ready to consider suggestions for revisions to its Practices. PIP cannot respond to questions requesting assistance in applying the requirements to specific designs. It appears that you may need to obtain the services of a technical consultant. Should you have suggestions for a revision to a Practice, please submit them with supporting technical information to this office. Very truly yours,

___________________ PIP Director cc: ( ) FT Leader

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FORM C
Proprietary/Specific Design Questions
(date) Ref: ( ) Mr./Ms. ( ) (company) (address) Dear Mr./Ms. ( ): We have received your inquiry of ( ). Please be advised that Process Industry Practices (PIP) issues interpretations in response to questions concerning the meaning of its Practices and is always ready to consider suggestions for revisions to its Practices. PIP does not approve, recommend, or endorse any such design or apparatus, nor does it limit the method of design or form of construction that might be used to conform to the Practice. It is not clear whether you desire an interpretation of some particular requirement in a Practice or a review (approval) of a proprietary or specific design, construction, or apparatus. Therefore, we cannot act on your inquiry. If you seek an interpretation of a requirement in a Practice, your question must be clearly stated and be confined strictly to the meaning of a Practice. Please resubmit your question, with particular reference to the requirements that seem to apply to your design (or construction), and present the full particulars of whatever requirement of the Practice you wish to have interpreted. Should you have suggestions for a revision to a Practice, please submit them with supporting technical information to this office. Very truly yours, ___________________ PIP Director cc: ( ) FT Leader

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FORM D Unclear Question

(date) Ref: ( ) Mr./Ms. ( ) (company) (address) Dear Mr./Ms. ( ): We have received your inquiry of ( ). Please be advised that Process Industry Practices (PIP) issues interpretations in response to questions concerning the meaning of its Practices and is always ready to consider suggestions for revisions to its Practices. In our opinion, your question is not clear enough to answer. Please resubmit your inquiry with additional information, or in a revised form, such that the question is clearly stated. Should you have suggestions for a revision to a Practice, please submit them with supporting technical information to this office. Very truly yours, ___________________ PIP Director cc: ( ) FT Leader

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FORM E
Rationale for Requirements Requested
(date) Ref: ( ) Mr. /Ms.( ) (company) (address) Dear Mr./Ms. ( ): We have received your inquiry of ( ). Please be advised that Process Industry Practices (PIP) issues interpretations in response to questions concerning the meaning of its Practices and is always ready to consider suggestions for revisions to its Practices. PIP does not respond to questions seeking the rationale for requirements in its Practices. These requirements are based on consideration of technical data and the judgment and skill of experienced engineering and technical personnel, representing both users and contractors, who serve on the Practice teams. Should you have suggestions for a revision to a Practice, please submit them with supporting technical information to this office. Very truly yours, ___________________ PIP Director cc: ( ) FT Leader

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FORM F
Question Requires Further Study
(date) Ref: ( ) Mr./Ms. ( ) (company) (address) Dear Mr./Ms. ( ): We have received your inquiry of ( ). Please be advised that Process Industry Practices (PIP) issues interpretations in response to questions concerning the meaning of its Practices and is always ready to consider suggestions for revisions to its Practices. Your inquiry has identified a potential need to revise a Practice. Resolution of your question will require further study by the responsible PIP Function Team (FT). If the decision is that no change is required, PIP will advise you accordingly. We appreciate your bringing this issue to our attention. Very truly yours, ___________________ PIP Director cc: ( ) FT Leader

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Appendix C Example Inquiries with Interpretations

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Example Inquiries with Interpretations

Example 1 purpose: To clarify a question concerning nameplates background: On a recent project, there was a disagreement concerning the rules for nameplates, particularly when an additional nameplate is specified. inquiry question: Does PIP VEFV1101, dated March 1997, prohibit the use of two nameplates, the manufacturers nameplate and a user-designated nameplate? interpretation: No. Example 2 purpose: To resolve what is meant by the word recommended background: PIP VECV1001 and other vessel-related Practices state that certain details or actions are recommended. It is not clear how to apply this type of statement. inquiry question: PIP VECV1001, 1997 issue, paragraph 5.13.3.2, states that the recommended gasket contact width be as shown in the table. Is this contact width mandatory? interpretation: No; however the values shown are recommended on the basis of experience and good engineering practice. Comment: It may be necessary to add a phrase after the Yes or No reply (as shown in Example 2) to help the inquirer. However, PIP Function Teams (FTs) should avoid acting as consultants.

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Appendix D Specific Function Team Inquiry Procedures

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CSA (later) Electrical (later) CIR (later) Mechanical (later) P&ID (later) Piping (later) Process Control (later) Vessel The Vessel Function Team (VFT) will use the following procedure to process all inquiries: 1. The PIP office will send all inquiries to the Co-Leader of the VFT. 2. The Co-Leader will modify the inquiry number assigned by the PIP office by adding a single letter suffix to distinguish between vessel, heat exchanger, tank, bin, and fiberglass equipment inquiries (i.e., V, E, T, B, F, respectively). 3. Every proposed interpretation must be reviewed and accepted by the following Inquiry Response Team members: the VFT Co-Leader, the VFT Leader, the applicable Task Team Leader, and depending on the subject of the inquiry, one member of the applicable task team, selected by the VFT Co-Leader. In addition, the Inquiry Response Team shall strive to include at least one oil industry owner member, one chemical industry owner member, and one contractor member. The makeup of this team may require that more than four members review inquiries. A unanimous ballot result is required for each inquiry review. If a unanimous agreement is not reached, the inquiry is to be elevated to the entire FT to review and ballot, when a majority vote is required for acceptance of the proposed interpretation. In an inquiry review by the entire FT, the Co-Leader will distribute the inquiry and the proposed response to the FT members in advance of the meeting. 4. The Co-Leader is responsible for preparing the initial drafts of all interpretations including the rewriting of the inquiry if required. If the CoLeader is not available to complete this task in the allotted time, the Leader shall assume this responsibility until the Co-Leader becomes available. No alternate members will be designated to serve in the absence of the other members of the Interpretation Task Team. The Task Team member selected should have some prior knowledge or involvement in the development of the applicable Practice, if possible, or be very knowledgeable on the subject of the inquiry. 5. The draft responses are to be routed, using e-mail, eRoom, fax, or regular mail, to the reviewing members. A copy of the original inquiry is to be provided to each reviewer as well. Distribution should not be delayed until a pending FT meeting. The reviewer comments are to be returned in similar fashion to the

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Co-Leader. The Co-Leader is to issue the approved interpretation and the inquiry question to the PIP office, using e-mail or fax, indicating that the interpretations are ready to be issued to the respective inquirers. 6. The results of the ballots will be reported by the Co-Leader at the next regular FT meeting and will be recorded in the minutes of this meeting. These results shall show the number of ballots received and the ballot tally. 7. The entire process of interpretation preparation and balloting is to be conducted on a fast-track basis, using electronic mail rather than waiting until regular FT meetings. Each inquiry should be returned to the PIP office in 3 months or less, if possible. 8. When an inquiry indicates a need to revise a Practice, the Co-Leader should indicate this need in the report made to the FT, which will determine whether an agenda item is required and will assign the item for action accordingly. If revision to a Practice is indicated, the PIP office will issue Form F to the inquirer. In the event that the agenda item does not result in a change to the Practice, the inquirer is to be issued a letter by the PIP staff, as advised by the Co-Leader, indicating that the committee decided to make no changes to the Practice as a result of the inquiry. 9. The Co-Leader will maintain a list of active inquiries, preferably in eRoom, indicating (as a minimum) the dates received, distributed, and issued and indicating any agenda items resulting from the inquiry. The list is to be used to assist the PIP office in tracking inquiry responses. The list should track inquiries that are as much as 10 years old.

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