When a gauge must be removed from a process unit, storage in an area that is dedicated only for gauges reduces the chances of the gauge being discarded with scrapped materials and equipment. An unused gauge that has been returned to a vendor is not at risk of being discarded into the recycling stream. Soft controls are less effective than hard controls in providing ICC because they do not always gain enough attention at the right times and they can be degraded by conditions and circumstances at facilities. Because regulations are necessarily broad and non-prescriptive, licensees have considerable leeway to devise their own control programs. Many licensees might benefit from learning about effective ICC practices.
Many factors placing the gauges at risk are outside the jurisdiction of regulatory agencies.
For example, regulatory agencies cannot direct licensees how to perform maintenance shutdowns, a circumstance where gauges might be discarded with scrap materials. Other factors cannot be completely controlled by licensees. For example, former employees cannot be told to implement the responsibility for gauges at a facility that has suddenly closed, a circumstance where gauges might be discarded when the facility is dismantled. This reality leaves a regulatory agency with the task of devising and communicating ICC practices that can be efficiently implemented. This reality also leaves licensees and the recycling industries with the responsibility for making business decisions to accept certain risks.