Chill - We Got This!
Known as the "PSM Evangelist" and the "Jon Taffer of Ammonia PSM," I have taught over 1,000 people how to implement PSM/RMP in their Ammonia processes. It is my honor and privilege to work with the finest minds in the industry. I fuse Six Sigma / Lean / Kaizen philosophy with PSM/RMP to minimize compliance burdens and maximize the safety & efficiency gains of a properly implemented program.
Here are some highlights:
- Designed, Built and Continuously Improved OSHA Process Safety Management, EPA Risk Management and Process Hazard Analysis Programs for Industrial Ammonia Refrigeration systems all over the country.
- Comprehensively audited OSHA Process Safety Management, EPA Risk Management in facilities throughout the United States in facilities of all sizes from 10,000 pounds to over 300,000. Processes ranged from Ammonia Refrigeration to N02 reduction and Synthetic Rubber production.
- Lead Author and Project Manager for the book “Implementing Process Safety Management for Ammonia Refrigeration” used as the textbook for teaching PSM for over 100 companies a year.
- Through FOIA, I have read the citations, 1B's and narratives to every PSM citation issued by OSHA from 2008-2013.
- Managed Refrigeration Projects including Expansions, System Optimization and Capital Projects.
- Acted as HazMat Incident Commander and Team Member.
- Skilled in Incident Investigation and Root Cause Analysis.
- Background in Six Sigma, Lean and Kaizen implementation in manufacturing.
- Familiar with ISO 9000 & SQF programs.
- Organized CMMS (Computerized Maintenance Management System) Implementation.
- P&ID creation and modification.
- Completed many projects in Energy Conservation and System Optimization of Refrigeration Systems.
(Apologies for the late post – a scheduled post did not happen. These changes took place 3/8/24)
The Various ITPMR’s, the Walkthrough Form & SOP, etc. were all re-reviewed line-by-line to ensure closer compliance with IIAR 6. Many, many changes were made based on this review. A detailed changelog follows:
Tomorrow is Ammonia (7/17) Day!
Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.
Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century Swiss philosopher.
“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel
While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.
Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.
Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.
Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.
“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen
To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!
IIAR 9-2020 Addendum A (202x) First (1st) Public Review
Public Review Announcement
IIAR invites you to make comments for IIAR’s first (1st) public review of IIAR 9-2020 Addendum A (202x) Safety Standard for Minimum System Safety Requirements for Existing Closed-Circuit Ammonia Refrigeration Systems.
Public Review Period: October 27th, 2023 through November 26th, 2023
Comments must be submitted to the IIAR Headquarters by 5:00 pm EST on November 26th, 2023. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.
You can review the document and make your voice heard at this link.
CFATS Announcement
As of July 28, 2023, Congress has allowed the statutory authority for the Chemical Facility Anti-Terrorism Standards (CFATS) program (6 CFR Part 27) to expire.
Therefore, CISA cannot enforce compliance with the CFATS regulations at this time. This means that CISA will not require facilities to report their chemicals of interest or submit any information in CSAT, perform inspections, or provide CFATS compliance assistance, amongst other activities. CISA can no longer require facilities to implement their CFATS Site Security Plan or CFATS Alternative Security Program.
CISA encourages facilities to maintain security measures. CISA’s voluntary ChemLock resources are available on the ChemLock webpages.
Today is Ammonia (7/17) Day!
Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.
Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century Swiss philosopher.
“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel
While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.
Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.
Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.
Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.
“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen
To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!
There are a lot of choices out there for fixed Ammonia Detection these days. Common brands include CTI, Manning / Honeywell, Danfoss, Bacharach, Draeger, Hansen, and CoolAir.
Obviously if you are installing a new detector in a General Duty or PSM/RMP covered process, you want to perform an equipment-level PSSR (pre-Startup Safety Review) for the detector. However, a common question we get is “does changing from one brand to another require an MOC?”
The root of this question is usually an attempt to justify the “change” as a “Replacement in Kind” and therefore avoid the paperwork of an MOC. But an MOC is not about PAPERWORK. An MOC is about thinking through the desired change (in a structured way) to see where problems can arise.
Put another way: Implementing the MOC procedure is how we answer the question of whether or not we need to document how we manage the change.
Let’s consider some things that might change when we replace one detector brand for another.
Sensor Type: Electrochemical, IR, Catalytic Bead, etc. Each of these types of sensors has benefits and drawbacks based on the conditions they are used for and in. If you are changing technologies, how does that change affect your process?
Sensor Range: Obviously the range of the sensor has an impact on how it works in your system. Replacing a 1-500ppm sensor with a 1-250ppm sensor without altering the system programming will report the wrong chemical concentration.
Signal Type / Range: Most sensor setups work on a 4-20mA signal, but some use Modbus or proprietary methods. You need to match your technologies or provide signal conversation.
Enclosure Rating / Environmental Considerations: Some sensors are subject to difficult environmental conditions such as blast-freezers and wash-down areas. You need to make sure that the sensor is suitable for the conditions you will expose it to.
Detector Placement: Manufacturer’s often provide recommendations on the height they want their detectors placed at. Make sure you are addressing those recommendations. If you are moving the Detector, are there any guarding considerations in the new location?
Inspections, Tests & Maintenance: Manufacturers have different inspections, tests and maintenance types and schedules. You must make sure you align to the manufacturers recommendations.
Bump Tests / Calibrations: Both the calibration method & frequency must be considered, including any unique calibration equipment and gases.
Conclusion: So, it’s possible that swapping a detector might well be a “Replacement in Kind” but there are a lot of things to consider before you arrive at that decision. You should use your MOC process to see if you need a formal, documented MOC.
Looks like the Biden administration is going to continue the recent streak of attempting to change the EPA RMP rules that was started in the Obama administration.
On August 18, 2022, EPA Administrator Michael S. Regan signed the Safer Communities by Chemical Accident Prevention (SCCAP) rule, which proposes revisions to the Risk Management Program (RMP) to further protect vulnerable communities from chemical accidents, especially those living near facilities with high accident rates. The proposed rule would strengthen the existing program and includes new safeguards that have not been addressed in prior RMP rules. Some of the proposed requirements include identifying safer technologies and chemical alternatives, more thorough incident investigations, and third-party auditing, all of which should benefit nearby communities. When finalized, the rule is expected to make communities safer by reducing the frequency of chemical releases and their adverse effects.
The public may comment on the SCCAP proposed rule at www.regulations.govEXIT EPA WEBSITE (Docket ID No.: EPA-HQ-OLEM-2022-0174) until 60 days after publication in the Federal Register.
7/17 Day is this coming Sunday!
Over the past few years, the obscure industry holiday has been catching on. On 7/17 day we celebrate the Ammonia (R717) refrigeration industry and all our colleagues.
Since it’s a fairly new holiday, I’d like to make a suggestion in hopes that it catches on in the industry. The inspiration for this suggestion is from a 19th century swiss philosopher.
“Thankfulness is the beginning of gratitude. Gratitude is the completion of thankfulness. Thankfulness may consist merely of words. Gratitude is shown in acts.” —Henri Frederic Amiel
While it’s fine to celebrate YOU and YOUR success on this day, I’m hoping we can eventually make it common-place to do these two things every year on 7/17.
Show Gratitude: First, I’d ask that you take some time to reflect on the people that helped you build your career. Those that took time to answer your questions; that gave you tips, criticisms, and guidance. Basically, anyone that went “above and beyond” what they had to do.
Take a few moments to reach out to them and let them know you appreciate how they’ve positively affected your life. Let them know their efforts paid off. Tell them they’re appreciated. Not only will you make them feel better about themselves, you’ll make it more likely they continue putting in that extra time or effort for new people in our industry.
Become a Mentor: Look around your workplace, community, church, etc. and find someone who could benefit from your time, thoughts, resources, or just your presence. Resolve to pay back some of the help you received along the way by supporting someone else on their journey. Because in those moments we spend for each other – and not just ‘with’ each other – we are giving a small piece of ourselves. The world need YOU and you will come to find that there is great value in service to others.
“…the only metrics that will truly matter to my life are the individuals whom I have been able to help, one by one, to become better people.” –Clayton M. Christensen
To all my Ammonia friends and colleagues: Thank YOU for all that you do. Happy 7/17 Day!
Public Review Announcement
IIAR invites you to make comments for IIAR’s public review of IIAR 1-202x Definitions and Terminology Used in IIAR Standards and IIAR 3-202x Ammonia Refrigeration Valves.
Public Review Period: March 25, 2022 through May 9, 2022
Comments must be submitted to the IIAR Headquarters by 5:00 pm EST on May 9, 2022. Substantive changes resulting from these public reviews will also be provided for comment in a future public review if necessary.
IIAR 1 is about definitions and may have some impact on those using the IIAR suite. IIAR 3 is about valves and is generally thought of as manufacturer-facing meaning it shouldn’t much affect you unless you are in the business of making refrigeration valves.
“Time Waits for No one…”
The Issue at hand
When I first started in NH3 refrigeration, you could pick up the phone, talk to your parts-guy, and get a replacement valve quickly: often the same day, but usually within a business day or two. While you were waiting for the part, you either operated the equipment manually (requiring a temporary SOP / MOC) or shut the equipment down during the wait. We call the time between when you order something and when it arrives, lead-time.
Because lead-times *were* short, parts inventory at most facilities were kept fairly low – usually limited to what would stop production. If you could get what you needed in a day or two, why keep it on the shelf, unless you were losing 20k+ an hour in downtime?
The situation has changed around us, and I’m not sure we’ve all thought through the implications of the current supply-chain issues. Lead-times have grown substantially in 2021 and, while relief is promised in the second half of 2022, these long wait times for equipment and components have the potential to adversely affect our Process Safety.
Current Lead Time estimates
| Equipment / Component | Lead-Times in Weeks* |
| Valves, Shutoff and Control | 14-24 |
| Valves, Relief | 12-20 |
| Vessels | 14-24 |
| Condensers | 14-16 |
| Compressors | 16 |
| Air Unit / Evaporators | 36 |
| Heat Exchangers | 14 |
*Typical for NH3 components. Varies by brand. Some halocarbons lead-times are even longer.
How can this affect Process Safety?
When you don’t have a critical spare part, and won’t have one for several months, production demands are likely to force you to operate your equipment in “temporary” modes. Here are a few thoughts:
What should I do?
“The first responsibility of a leader is to define reality…” –Max DePree
Well, the first step is to start a discussion with your skilled technicians and make sure they understand the environment we’re all working in. Here are some points for discussion, and further actions to take:
RC&E can assist you with your parts and spares. Click Here for our Line Card. Call Dennis Vaught 817-210-1957 or email him at [email protected]
