RC&E Chill - Industrial Refrigeration and Process Safety / Risk Management

Chill - We Got This!

Author: Brian D. Chapin (Page 10 of 13)

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.

Forklift Fatality

September 27, 2017 /

“A 58-year-old Hispanic lumberyard worker died on March 30, 2012, from crushing injuries received when a forklift driven by a coworker struck him. The lumberyard laborer was walking from his work area to the employee lunchroom. At the same time, and in the same area, a coworker was operating a forklift that was loaded with lumber. The forklift operator’s field of vision was limited because he was transporting the lumber “load-forward” and the load partially obscured his view. He did not see the laborer but stopped when he felt the forklift roll over something. He exited the cab and found the laborer unresponsive, lying near the left side of the forklift. The laborer was pronounced dead at the scene. The medical examiner identified head and thoracic injuries as the cause of death.” —NIOSH FACE

This unfortunate incident is not Process Safety related, but MANY NH3 processes are located in Cold Storages and Food plants that have MANY forklifts. If YOU work in such a place, please share this information with your co-workers and Occupational Safety team. Hopefully, sharing it can serve as a reminder that you shouldn’t drive forklifts with an obstructed view.

The Cyrus Shank LQ Series Relief Valves – A Discussion on Manufacturer’s Recommendations and the 5 Year Pressure Relief Valve Interval

September 11, 2017 /

Many facilities I’ve been to recently use the Cyrus Shank LQ Series valves for internal/liquid relief applications. At these facilities, there tends to be some confusion on the 5-year replacement schedule since these are internal relief valves but still come with a replacement date tag.

Allow me to explain the conflict here:

Back in 2007, the IIAR issued a revision to their Bulletin 110 (Start-up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems) which clarified the current standard on replacing or recertifying pressure relief devices. It states that you have 3 options for setting your relief valve replacement schedule:

  1. Every five (5) years from the date of installation. IIAR originally recommended (in 1978) that pressure relief valves be replaced every five years from the date of installation. This recommendation represents good engineering practice considering the design and performance of pressure relief devices; or
  2. An alternative to the prescriptive replacement interval, i.e., five years, can be developed based on documented in-service relief valve life for specific applications using industry accepted good practices of relief valve evaluation; or
  3. The manufacturer’s recommendations on replacement frequency of pressure relief devices shall be followed.

It’s a fairly straightforward list that led to both facilities and manufacturers setting a replacement schedule not to exceed 5 years unless conditions warranted earlier replacement of the devices. The major follow-up question for schedulers is what to do with internal or liquid relief valves, since they’re not usually subject to the same concerns as atmospheric relief valves.

The same IIAR bulletin covers this as an exception to the previous recommendation, stating that:

“Relief devices discharging into another part of the closed-loop refrigeration system are not subject to the relief valve replacement practices.”

Internal relief devices come in many configurations, so relief valves designated for liquid use are normally treated the same as relief regulators or similar devices in that they aren’t replaced until a regular inspection (or system operation) indicates the need.

Generally speaking, when we set our mechanical integrity schedule we first check the standards (IIAR Bulletin 110 in this case) and then modify that schedule based on the manufacturer’s recommendations for our specific equipment. The issue that occurs here is that the Cyrus Shank bulletin issued for their relief valves recommends that they be replaced at least every five years, without specifying which type. After contacting Cyrus Shank, their engineering department responded with the following:

“The cut sheet is a general recommendation that would apply to all of our valves, including the LQ valves. There is one difference between the vapor service valves and the liquid (LQ) ones: the LQ valves have a slightly different sealing ‘surface’ as compared to the vapor. Other than that, they are essentially the exact same in design. The replacement/inspection intervals greatly depend on the nature of the contents and operation of the system so only general recommendations can be given.  We would still recommend the general 5 year replacement interval for both the vapor AND liquid service valves regardless of application. However, the replacement interval is ultimately up to the customer. “

To be consistent with the other justifications in our (manufacturer recommendations based) mechanical integrity schedule, that means that we’ll be replacing those LQ Series valves at least every five years as well. It’s important when setting up a compliant program that we stay informed of all the different RAGAGEP sources that can affect our program. The exception in IIAR Bulletin 110 actually does allow us to set our schedule based on a method of our choosing, but our justification must be defensible. Our defense normally comes from the manufacturer recommendation, so in this case we would have to follow the 5-year recommendation on LQ valves as our RAGAGEP.

10/10/17 Update: Some people have suggested that statements from Cyrus Shank marketing materials somehow override the statements of the Cyrus Shank engineering department. This is absurd and a fundamental misunderstanding of RAGAGEP. If the Cyrus Shank engineering department changes their position then this issue can be re-evaluated, but until then it remains as shown above.

For more on this topic, click here.

11/09/18 Update: Cyrus Shank has helped us deal with this issue!

 

PHA Template Revisions

August 2, 2017 /

The Template What-If / Checklist worksheet used to guide PHA Studies has been modified.

  1. The Identification and Review of Past Incidents section has been renumbered with some new questions concerning the performance of the Incident Investigation element added before the example / industry What-If incident questions.
  2.  We’ve added a new 57-question Revalidation Considerations Checklist to the current list of What-If questions. This new section is to be used as an additional check on PHA revalidations.

These changes are available immediately to anyone using the Google Shared Drive.

Note: These additions are partially based on an EPA-provided example of typical questions asked during a PHA revalidation. It has always been our practice to FULLY revalidate the PHA by reviewing all the previous answers; however, during a revalidation, this new section should help highlight areas of the existing PHA study that demand extra attention.

Why we changed the name of our element “Guidelines” to “Written Plans”

July 28, 2017 /

In mid-february we changed every reference to Guideline in the example templates to Written Plan. This change was made to the Google Drive and logged on 2/3/17.

Although I have used the term guideline for a very long time, it was really just out of habit – it’s not an accurate reflection of the intent of those documents.

First: Where did this Guideline idea come from?

Well, it all started back in the Employee Participation element which requires you to have a document that explains how you intend to comply with certain requirements.

1910.119(c)(1) – Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph.

Over time we realized that these written plans of action were very useful and wrote them for every single PSM/RMP element. For whatever reason, the very first program I ever worked on called this the “Guideline for Employee Participation” and I just stuck with that wording for well over a decade.

Ok, so why call it a Written Plan rather than a Guideline?

Well, let’s look at definitions:

A dictionary definition of guideline is:

“General rule, or piece of advice”

The word plan defined in that same dictionary:

“a detailed proposal for doing or achieving something;”

“an intention or decision about what one is going to do.”

The word plan is really what we are going for: A decision about what the facility is going to do. The intent of these documents, whether they are called Written Plan or Guidelines, was always to document the detailed plan that the facility intended to follow in achieving compliance.

Anything else?

Actually, yes. Over the years we had to explain the above to several different inspectors: our Guidelines were actually our written plans. Frankly, it just got annoying explaining the same concept over and over again – especially when they had a point: Rightly understood the documents really are the written plan and general guidance usually used the guidelines terminology such as the IIAR Compliance Guidelines and the CCPS Guidelines for Safe Process Operations and Maintenance.

Do I have to change my documents if I use the templates?

Well, no you never really have to update your program to reflect our changes. That said, Should you? Yes, you should make the change whenever you update your program to the latest templates.

What training does my refrigeration operator need?

July 11, 2017 /

Note: this article focuses only on the PSM/RMP training burden that is unique to PSM/RMP. Furthermore, it does not address the requirements of training documentation.

Understanding the requirements of PSM/RMP training for Operators

The Training element in PSM (1910.119(g)) and RMP (40CFR68.71) requires that your process operators involved in operating a process receive certain training. For me, the key word for our understanding is Operator which means to control the functioning of a machine, process or system. If they turn valves, operate physical or electrical controls, etc. they are likely Process Operators. It is important to remember that the term Process Operator is not a title – it is a function. A management employee that turns refrigeration valves, or restarts equipment after a power failure is a Process Operator by function even if their title is “Director of Warehousing.” This concept is so important, that it is one of our PSM Golden Rules:

8. Treat people by their function within the process, not their title.

This means that in facilities where Contractors are actually the Process Operators, this Operator Training section must apply to them – just as it would a similarly situated direct-hire employee. OSHA made this clear in 1992:

…should a contract employer provide employees to operate a process, then those employees would obviously have to be trained to the same extent as the directed hire employees “involved in operating a process” under paragraph (g) of the final standard.

Generally speaking, all OSHA standards cover all employees including contract employees. In something of a break with tradition, the process safety management rule has separate provisions covering the training of contract employees. This was done primarily for emphasis since contract employees make up a significant portion of some segments of industries covered by the final rule. This is not to say, however, that paragraph (h) is the only section of the process safety rule that applies to contractors. As already indicated, under appropriate circumstances, all of the provisions of the standard may apply to a contractor (i.e., a contractor operated facility). After all, employees of an independent contractor are still employees in the broadest sense of the word and they and their employers must not only follow the process safety management rule, but they must also take care that they do nothing to endanger the safety of those working nearby who work for another employer. Moreover, the fact that this rule has a separate section that specifically lays out the duty of contractors on the job site does not mean that other OSHA standards, lacking a similar section, do not apply to contract employers. (OSHA, PSM Preamble, 1992)

Training in this element that training is broken into two categories: Initial and Refresher.

Initial Training

Initial training is 1910.119(g)(1)(i) – “Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks“

Initial Training is meant to cover the things Process Operators need to know to be involved in the covered process. It needs to cover an Overview of the Process as well as any specific Operating Procedures that the Process Operator is expected to perform.

One component of the Overview of the Process. Overview of the Process is simply how the covered process works. This understanding can be very basic or in-depth based on how much the Process Operator needs to know to safely perform the tasks assigned to them. This is the only component of the operator training requirements that is addressed by attending 3rd party classes (usually titled Refrigeration Operator) at a one-week school. I’m not discounting their value – I’m just pointing out that these schools do nothing to meet the other requirements of the training element. (Any honest school offering these classes will tell you this!)

This operator training must include a focus on:

  • Specific Safety and Health Hazards of the process and work on the process.
  • Emergency Operations and Shutdown.
  • Safe Work Practices (Like LEO & LO/TO) applicable to the employee’s job tasks.

It’s important to emphasize that this training is conducted before the operator actually performs these tasks independently. For a typical Ammonia Refrigeration Process Operator, these requirements would lead us to train, at a minimum, in the following areas:

  • Routine refrigeration system operation; an overview of the process.
  • Ammonia properties, safety and health hazards
  • SOP awareness including the requirement to follow written SOPs
  • Specific training in any SOP they are expected to perform such as the Overall System Operation SOP(s), which includes emergency and normal refrigeration system operation procedures.
  • Their individual role in the emergency response plan

In many programs, this is a level of Process Operator called Entry Level. Due to the increased use of Contractors in most Ammonia Refrigeration processes, many, if not most, Process Operators are never trained to reach higher levels of operator classification.

Refresher Training

1910.119(g)(2) – “Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training.” Note that this training is meant to reinforce the earlier emphasis on SOPs.

Refresher or Ongoing Training is a collection of activities designed to reach a certain Performance-Based goal: …To assure that the employee understands and adheres to the current operating procedures of the process.

The “understands” portion of the performance basis should have been handled by our Initial Training. The real question then is how we ensure Process Operators adhere to current operating procedures of the process. This is called Operational Discipline. Much of what we call Refresher Training is just reminding Process Operators about the importance of this Operational Discipline. An example Refresher Training schedule is below:

In addition to the above regularly scheduled and event-driven training, there should be some sort of verification that process tasks are being completed in accordance with the written procedures of the process. On a regular basis (usually at least annually) the Responsible Person should verify that qualified operators are adhering to the SOPs. This verification usually takes the form of observations while the operator performs their assigned work. These observations should be done without prior notification of the operator being evaluated.

While there is a requirement that Refresher Training occur at least every three years, and that the frequency of the training be decided in consultation with the Process Operators, an effective PSM/RMP Program is continuously Training and seeking consultation.

Employers, in consultation with employees, shall determine the appropriate frequency, which may be based on consideration of such factors as deviations from standard operating procedures, recent incidents, or apparent deficiencies in training. (OSHA, CPL 2-2.45A, 1994)

Mechanical Integrity (Maintenance) Training

1910.119(j)(3) – “Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee’s job tasks to assure that the employee can perform the job tasks in a safe manner.”

In this section they are referring not to the SOPs so much as the written procedures required in 1910.119(j)(2) – “Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment.”

The rule requires that there be written procedures on maintaining the integrity of the covered process and that the personnel performing these procedures be trained in those procedures. Most chemical and petroleum plants have one set of personnel to operate the plant and another to maintain it. Nearly all Ammonia Refrigeration systems have the same personnel operate and maintain the process, so most plants in our position combine these training requirements with the Operator Training requirements.

As OSHA indicated in the preamble, paragraph (j)(3) requires that employers provide maintenance employees with “on-going” or “continual” training adequate “to assure that they can perform their jobs in a safe manner.” In this regard, the paragraph clearly contemplates that new maintenance employees be trained before beginning work at the site, and all maintenance employees receive additional training appropriate to their constantly changing job tasks. (OSHA, CPL 2-2.45A, 1994)

Appendix C to the rule notes that the “employer needs to develop procedures to ensure that tests and inspections are conducted properly and that consistency is maintained even where different employees may be involved. Appropriate training is to be provided to maintenance personnel to ensure that they understand the preventive maintenance program procedures, safe practices, and the proper use and application of special equipment or unique tools that may be required. This training is part of the overall training program called for in the standard.” (OSHA, 29CFR1910.119, 1992)

Note that this includes contractors that are performing MI tasks on the covered process:

This training requirement applies to both host employer’s and contractor employer’s employees performing MI procedures. CPL 02-02-045, Appendix B, pg. B-27, states, “If contract employees are involved in…maintaining the on-going integrity of process equipment, then they must receive training in accordance with specific training requirements set forth in paragraphs (g) and (h), respectively”). (OSHA, Refinery PSM NEP, 2007)

What does a successful training program look like?

A successful Operator Training element will be one that:

  • Ensures the operators are aware of the procedures and will consistently apply those written procedures resulting in fewer process deviations.
  • Ensures the operators understand the process and the procedures so they are able to quickly correct those few deviations that do occur.

“An effective training program significantly reduces the number and severity of incidents arising from process operations, and can be instrumental in preventing small problems from leading to a catastrophic release.” (OSHA, CPL 2-2.45A, 1994)

 

Updated EPA rule officially delayed until at least February 2019

June 12, 2017 /

Note: See December 2019 Update.

The Environmental Protection Agency (EPA) will delay implementation of an Obama-era chemical safety rule for nearly two years while it reassesses the necessity of the regulation.

The EPA announced on Monday that Administrator Scott Pruitt signed a directive last Friday delaying the chemical plant safety standards until at least Feb. 20, 2019.

Source: The Hill

Previous Coverage:

040217

Updates:

051718

081718

Yet another sign!

May 8, 2017 /

Many, moons ago when I was a volunteer firefighter, we came up with a slogan for our crew: Perfection is Our Goal. Excellence will be Tolerated.

Today, I turned that into a PSM sign if you are interested.

How to prepare for an Inspection

May 3, 2017 /

For those of you that wanted the slides from the “How to prepare for an Inspection” presentation that was given by me at the 2017 DFW Regional RETA conference, the link is below:

2017 DFW Regional Conference PPT – Chapin 031317

Depending on your area you may get anywhere from five days up to six weeks notice for a scheduled  inspection from the EPA. You aren’t going to create a compliant, living PSM/RMP program in that time frame but there are many things you can do to prepare the program you already have. Assuming you have a level 3 program in conjunction with a PSM program, here are three things you absolutely should do if you get notice of an inspection:

Synopsis from a 2012 post on another site:

What should you do if you get a notice of an EPA Risk Management Program inspection?

1) Know your material.

  • The RMP Level 3 checklist that most EPA inspectors use is freely available online. Go through it and make sure you have these items covered in writing and that you know where to find them quickly.
  • Check your documentation for accuracy: Every document you use to answer the questions in the RMP Level 3 checklist should be checked for accuracy. Are you doing the things the documents require in the way you say they will be done?
  • Check for open recommendations. Whether they’ve been generated through Employee Participation, Incident Investigations, Process Hazard Analysis, Compliance Audits or any other source, make 100% sure that you have addressed every one of these recommendations. You don’t need to have every one of them closed, but you need a plan of action and a schedule for those actions in writing.

2) Prepare the staff – including yourself.

  • Make sure everyone is aware that an inspection is going to happen.
  • You don’t want to be tripping over contractors so you may wish to schedule their work at times that don’t coincide with your inspection.
  • Remind your staff to “GO TO THE DOCUMENTS” in response to any PSM/RMP question.

Q: “How do you drain this oil pot?”

A: “With this written procedure.”

Q: “How much ammonia is in the system?”

A: “This inventory calculation sheet has the information you are asking for.”

  • Handle this as a professional learning opportunity and you’ll do much better. Rather than having a surly demeanor and saying “What do you want?” to an inspector, why not something more like “We put a lot of effort into our PSM/RMP program to protect our employees and the environment. We’re really looking forward to this opportunity to show you all the hard work we’ve been doing and perhaps find some ways we can further improve it in light of your experience.” Now you’ve complimented the inspector and expressed your company’s desire to meet the goals of the program – nobody loses there.
  • Relax: Remember they are auditing a program – not the people who implement it. It’s important that you take the inspection seriously but it’s not the inquisition. Don’t relax too much: I know of several inspections that went downhill rapidly because the staff were treating the inspection as a joke.
  • Put yourself in their shoes for a second. Inspectors are generally good people trying to do a good thing – treat them as professionals. There are appropriate venues to vent your feelings on the federal or state government – the inspection is not one of them. Inspectors are used to being treated awfully so why not be the exception and treat them as a welcome guest?
  • On the flip side – STAND YOUR GROUND. Support your program and your compliance efforts with RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) so the inspector is left to argue with the CCPS or the IIAR rather than you personally. Often inspectors will want to see something a certain way. When you are having an issue meeting their demands, ask them exactly what portion of the law they are referring to. PSM/RMP is a performance oriented standard – they picked the destination but your company gets to pick the path you take to that destination.

3) Prepare the facility

  • Part of the inspection will include a site tour. This is no different than a visit from your mother in law – you will want to put your best foot forward.
    • Plan out your route so the inspector gets to see everything they need to see while showing the facility in the best light.
    • Do some dusting, painting, re-labeling and tagging as needed. A little bit of housekeeping goes a long way in establishing good will.
  • LOOK at your system. A dented drain pan will draw questions about “struck-by hazards”, a fresh weld and unpainted pipe will draw questions about Management of Change, frost on insulation will draw questions about Corrosion Under Insulation and Non-Destructive Testing, etc. Be prepared for these questions and have ready answers.

The steps above WILL prepare you for an EPA inspection and they WILL improve your results. What they can’t do is cover up a program that has been neglected for years, but if you are reading this then that’s probably not your situation. Almost any program that has not been completely neglected can be improved and polished enough to pass most EPA inspections with the help of a great compliance consultant.

If you find yourself in need of some advice, some pre-audit assistance or a compliance audit / gap analysis, you can always call on your favorite resource for some assistance before the inspection. I would love to hear from you and help you prepare. You don’t have to be in this alone!

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