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General Duty vs. PSM/RMP: Is there a benefit to dropping below the 10,000lb threshold?

February 26, 2018 /

Several times a year I get a phone call or an email from a client that wants to lower the NH3 inventory below the federal 10,000lb threshold so they are no longer subject to the PSM/RMP rules. It’s a conversation I’ve had nearly a hundred times over my career, so I thought it would be worth writing down my thoughts on this subject for posterity. The factors break down into three categories: Logistical, Regulatory and Safety.

Logistical: If you’re close to the 10,000lb threshold, you may be able to reduce the NH3 inventory below the regulatory line of 10,000lbs., but there are some things worth considering:

Is it safe? A system operating below the level it was designed to operate is often called starved. Starved systems can be unsafe due to the increased rates of vapor propelled slugging and low vessel levels causing pumps to cavitate. This isn’t something you want to do without consulting a design engineer.

Can I keep it at this level? If we dropped our system inventory to 9,900lbs., we are going to have to ensure it stays below the 10,000lb threshold or we can end up in a regulatory nightmare. Future charges (to replace losses) will require careful calculation to ensure that we stay on the right side of the threshold. This can be done through a good inventory management program, but it’s something you’re going to want to plan for.

Regulatory: If we drop below the 10,000lb threshold, we can remove ourselves from the federal RMP & DHS registries, but we will still have to meet the OSHA and EPA General Duty requirements for our NH3 refrigeration system.

To quote OSHA:

“Employers can be cited for violating the General Duty Clause if there is a recognized hazard and they do not take reasonable steps to prevent or abate the hazard.”

When we discuss things like “recognized hazard” we are discussing the things that are outlined in appropriate RAGAGEP. What would be RAGAGEP for an NH3 refrigeration system below 10,000lbs? At a minimum, ALL the IIAR standards & bulletins as well as the IIAR ARM (Ammonia Refrigeration Management) program. What does that mean?

  • The system design still has to comply with IIAR 2 Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems
  • The installation still has to comply with IIAR 4 Installation of Closed-Circuit Ammonia Refrigeration Systems
  • The startup and commissioning still has to comply with IIAR 5 Start-up and Commissioning of Closed-Circuit Ammonia Refrigeration Systems
  • The process safety information and maintenance program still has to comply with IIAR
    • Bulletin 108 Guidelines for: Water Contamination in Ammonia Refrigeration Systems
    • Bulletin 109 Minimum Safety Criteria for a Safe Ammonia Refrigeration System
    • Bulletin 110 Guidelines for: Start-Up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems
    • Bulletin 114 Guidelines for: Identification of Ammonia Refrigeration Piping and System Components
    • Bulletin 116 Guidelines for: Avoiding Component Failure in Industrial Refrigeration Systems Caused by Abnormal Pressure or Shock
    • The upcoming IIAR Standard 6 Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems which will replace all the above bulletins
  • The operating procedures still has to comply with IIAR 7 Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems
  • The overall system safety management program will have to comply with the IIAR ARM program which is about 90% of the paperwork burden of a full PSM/RMP program.

If you are looking at that list and thinking “There’s almost no benefit to dropping below the 10,000lbs mark from a regulatory standpoint” you aren’t wrong. There is ONE and it’s fairly minor: Generally speaking, your potential fines for violating OSHA’s or EPA’s General Duty clause are smaller than those for violating PSM/RMP. I say generally, because that’s not always the case. As an example, here’s a consent agreement for a $185,000 fine under the EPA’s General Duty clause.

Let me summarize the regulatory situation of a General Duty NH3 refrigeration facility in a single sentence: A General Duty NH3 refrigeration system is going to have 95% of the regulatory burden of a PSM/RMP facility (and thus have to do the same things as a PSM/RMP facility would) but you won’t have the well-understood PSM/RMP structure to help manage that regulatory burden.

Safety: In theory, any inventory reduction provides some small measure of reduced risk. In practical terms, though, there is usually very little effect. Often, due to the way our systems are designed (and the way the RMP scenarios are calculated) there is no change at all in the calculated area of effect of a release scenario*. Also, it’s important to keep in mind that very small amounts of NH3 can pose a danger to your personnel – it doesn’t matter that you’ve reduced your inventory from 11,000lbs to 9,900lbs when a release of 5lbs can pose mortal danger to a technician.

In my experience though, the real danger of reducing your inventory below the threshold is that facilities that do so almost always give their General Duty compliance a lower priority than they gave to their PSM/RMP compliance. These facilities become less safe because they believe that they are less exposed to OSHA and the EPA.

Conclusion: Yes, lowering your inventory can produce a slight increase in inherent safety and a lower regulatory exposure, but in practice, it usually does very little other than give the facility an excuse to de-prioritize safety and compliance.

I work with many companies with National and International brands. Nearly ALL of these companies treat their General Duty facilities as if they have over the 10,000lb threshold, for the same reason: Brand protection – You never want to be in a position where you are making the argument that you didn’t provide the highest level of safety to your employees and your community because you didn’t have to by law!

* No, Worst-Case and Alternate release scenarios are not required by General Duty plants, but I always calculate and map them so the facility understands the possible ramifications of a release on their community.

 

2019 UPDATE: The chart below shows the differences between the PSM/RMP requirements (as of July 2019) and the recently published 2018 ARM program. The compliance burden for ARM is roughly 90-95% of PSM/RMP due to the IIAR Standards and existing OSHA/EPA requirements OUTSIDE of PSM/RMP.

 

OSHA PSM & EPA RMP vs. GDC and IIAR’s 2018 ARM Program
PSM/RMP element Equivalent IIAR ARM (GDC) What’s the difference?
RMP & Hazard Assessment

·        Management System

·        WCS/ACS Scenarios

·        RMP Filing

 Management System

Hazard Assessment

 There is no RMP CDX filing, but the ARM requires that you calculate the WCS/ACS scenarios and establish a Management System. This is roughly 90% of the RMP burden.
Employee Participation NONE While the ARM doesn’t require this as a stand-alone element, the PSM/RMP burden for the element is fairly light. It is unlikely that ANY safety program would be functional without adequate employee participation.
Process Safety Information Refrigeration System Documentation No significant differences because the ARM references IIAR 2 & 9 which reference all the installation standard (IIAR 4) and the startup standard (IIAR 5) and the MI Standard (IIAR 6). Functionally identical to PSM/RMP.
Process Hazard Analysis Hazard Review No significant differences because the ARM references the IIAR What-If/Checklists. Functionally identical to PSM/RMP.
Procedures Operating Procedures No significant differences because the ARM references the SOP standard (IIAR 7). Only missing requirement is the annual SOP certification. This is roughly 99% of the PSM/RMP burden.
Operator Training Training Program No significant differences because the ARM has all the same requirements and references IIAR ARTG. Functionally identical to PSM/RMP.
Contractors Contractor Program No significant differences other than the lack of a requirement for a Contractor Injury Log. This is roughly 99% of the PSM/RMP burden.
Mechanical Integrity Preventative Maintenance Program No significant differences due to the requirements of ARM and the fact that the ARM references IIAR 2 & 9 which reference all the installation standard (IIAR 4) and the startup standard (IIAR 5) and the MI Standard (IIAR 6). Functionally identical to PSM/RMP.
Hot Work NONE Since OSHA requires Hot Work outside of the PSM standard, this is pretty much identical to the PSM/RMP burden. 
Management of Change and Pre-Startup Safety Review Managing Change No significant differences due to the requirements of ARM and the fact that the ARM references IIAR 2 & 9 which reference all the installation standard (IIAR 4) and the startup standard (IIAR 5) and the MI Standard (IIAR 6). Functionally identical to PSM/RMP.
Incident Investigation Incident Investigation ARM doesn’t include the new Obama-Era RMP requirements, but neither does PSM. Until the EPA publishes new GDC guidance we won’t know if ARM needs this too. Since the new EPA requirements were already done by most functional programs, there is very little change. This is roughly 95% of the current PSM/RMP burden.
Emergency Action / Response Emergency Planning & Response ARM doesn’t include the new Obama-Era coordination with local responders, but neither does PSM. Until the EPA publishes new GDC guidance we won’t know if ARM needs this too. Because the OSHA requirements are outside of PSM, this is all of the OSHA (PSM) burden and roughly 90% of the RMP burden.
Compliance Audit Self-Audits The only difference is the lack of a “certification” requirement. Note: ARM doesn’t include the new Obama-Era RMP 3rd party audits in the case of a 5yr History recordable accident, but neither does PSM and this requirement is still postponed until 2021. Until the EPA publishes new GDC guidance we won’t know if ARM needs this too. This is roughly 99% of the current PSM/RMP burden.
Trade Secrets NONE ARM doesn’t require an element for this, but since there are VERY few Trade Secrets in NH3 Refrigeration, it doesn’t much matter.

Updated MI / II Written Plan templates

November 20, 2017 /

The Mechanical Integrity and Incident Investigation Written Plans were updated this week to encompass the addition of an Acceptable Task Frequency Window. Essentially, this provides written guidance on task-scheduling slippage. The majority of the change is in the MI element:

Note that this written guidance directs you to the Incident Investigation element if you find that tasks are sliding outside the acceptable window. The only change in that element was to provide this schedule slipping as an example of an event that should be considered a Process Upset/Interruption.

A hat tip to the IRC at the University of Madison Wisconsin for bringing this idea to our attention in their excellent book Principles and Practices of Mechanical Integrity Guidebook for Industrial Refrigeration Systems. We’ve somewhat altered their suggested schedule and our integration into the standard template program wraps it into the Incident Investigation element to deal with those times that our tasks slip outside the acceptable task frequency window. 

As always, the updated Written Plans are available on the shared drive.

Update: Minor change made to the PHA Element Written Plan to correct a numbering issue. Thanks Mindy!

Improvements made to the Employee Participation Written Plan template

October 23, 2017 /

For several years we’ve noticed that many facilities has an unwritten / informal policy regarding SWA or “Stop Work Authority.” What is SWA? Simply put, SWA is a formal declaration that employees have the right (and obligation) to stop unsafe work when they become aware of it.

While the safety culture at most facilities implies that employees have Stop Work Authority, it is rare to see a written plan that addresses it. Since we believe that SWA is a vital part of a functioning safety culture, we have written it directly into the Employee Participation element’s Written plan.

If you use our PSM/RMP templates, you will find the updated documents on the shared drive. Below is an excerpt of the policy section:

The Written Plan includes an explanation of each step in the process.  We’ve also included a poster to be used in the workplace:

RAGAGEP Hierarchy in Application – A worked example

October 10, 2017 /

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices/Principles) is extremely important to our Process Safety programs as it helps define the boundaries of what is (and isn’t) acceptable in our processes and our management of them. There seems to be some confusion in a significant portion of the industry as to how to practically apply RAGAGEP* so I thought a brief discussion (and worked example) might be useful.

Let’s say that we have multiple possible RAGAGEP’s for a single item – such as relief valve replacement schedule. Those multiple RAGAGEP’s may well have differing requirements so we will need to rank them to understand what we actually need to do. Here’s an example RAGAGEP listing from OSHA:

  1. Codes adopted by the AHJ (Authority Having Jurisdiction) such as IMC/UMC
  2. Consensus Standards such as IIAR or ASHRAE
  3. Non-consensus documents such as Pamphlets / Bulletins from industry organizations
  4. Internal Standards such as your corporate policy

What isn’t on that list is manufacturer’s recommendations and there’s a reason why. The things listed above set the RAGAGEP and the manufacturer’s recommendations can modify it.**

There are generally two ways to modify something: make it more or less restrictive.

More: In the event that the manufacturer gives you a recommendation that is more restrictive (conservative) than the RAGAGEP, you must*** accept that more restrictive recommendation.

Less: If the manufacturer gives you a recommendation that is less restrictive than the RAGAGEP, you can accept that less restrictive recommendation, but you will need to document why you believe that the manufacturer’s recommendation is superior to the existing RAGAGEP.

In a recent article, we discussed the replacement schedule for a relief valve that relieves back into the system. The codes reference the consensus standards, which in turn reference some non-consensus bulletins. The bulletin in question, IIAR B110 says that these valves are not subject to the 5yr changeout frequency that other relief valves are. Yet, we have an email from the manufacturer’s engineering department that still recommends the 5yr changeout schedule.

In this case, we have a disagreement between the non-consensus bulletin and the manufacturer’s recommendation. Put another way, we have a generic recommendation on relief valve changeout versus a manufacturer specific recommendation. Obviously, the manufacturer’s specific recommendation on their valves overrides the generic recommendation about all relief valves. Therefore, as long as we are going to use these specific valves, we need to follow the manufacturer’s recommendation. ***

*It’s important to understand that we’re talking about what RAGAGEP decision is the most defensible during an inspection / audit.

** In 1910.119(j)(4)(iii) manufacturer’s recommendations are explicitly called out in conjunction with good engineering practices to set inspection/testing frequency, but the point still holds true.

*** It’s theoretically possible that you can make the engineering case that you know more about the manufacturer’s equipment as it operates in your process than they do, so you can override their recommendation. One method that’s routinely used is to choose an alternative way to achieve the same goals – one where you can show the engineering rationale to prove your alternative is as safe or safer. A common example of that would be replacing the oil based on regular oil analysis rather than changing it out at a specific hour interval. Of course, such a change would have to be thoroughly documented through your Management of Change procedure.

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.

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.

Why does my PSM program make me review the PHA during any equipment/facility MOC?

February 13, 2017 /

Nearly two years ago, I changed the Management of Change Written Plan template in my PSM programs to make a few changes:

  • Removed the “minor change” and “major change” categories.
  • Explicitly require a Process Hazard Analysis review during all equipment/facility MOC’s.
  • Explicitly require a Pre-Startup Safety Review (PSSR) before startup for all equipment/facility MOC’s and suggesting that it be conducted by someone other than the person that performed the MOC procedure.

These changes are related and they were made for a few reasons, which broadly break into three categories:

  1. PSM Guidance History
  2. Lessons Learned from Audits, Citations, and Incidents
  3. Plan Simplification

PSM Guidance History: There are two main ongoing issues with the NH3 refrigeration industry’s understanding of MOC. The first is the fiction that there are “minor” and “major” categories of changes in the PSM/RMP rules. It seems that the example written plan provided in the first edition of the IIAR Compliance Guidelines has been so internalized into our industry that people have stopped looking at the actual regulations or guidance documents from OSHA & the EPA. Essentially, the IIAR guidance splits changes into either “minor” or “major” based on whether they invalidate the PHA. If they do invalidate the PHA, they are “major” changes, and if they don’t, they are “minor” changes. This (arguably useful) fiction is NOT present in the PSM/RMP MOC rules.

Here’s the relevant IIAR guidance on “minor” changes:

“When processes undergo minor changes (e.g., minor rerouting of a piping run), information is typically added to a PHA file to reflect the change, even though the validity of the PHA is not affected by the modification.”

Here’s the relevant IIAR guidance on “major” changes:

“A major change is a modification which has significant impact on process conditions or system parameters and was not addressed by a previous Process Hazard Analysis (PHA) study.”

If that’s your policy, then the IIAR is already telling you that the PHA should be reviewed during the change. Why? How could you possibly know if the change “was not addressed by a previous PHA study” or whether the “Validity of the PHA is not affected by the modification” without reviewing the PHA?

Since the IIAR guidance (and experience) tell us we have to review the PHA as part of the change, there is little benefit to the IIAR scheme of “minor” and “major” changes. You can’t justifiably determine which category the change falls into until after you’ve reviewed the PHA. Unfortunately, that’s not what was happening…

Lessons Learned: PSM covered facilities have a LONG history of failing to properly manage changes. You would be stunned to see some of the changes that occur in covered processes without undergoing an adequate MOC procedure – or without any MOC at all. We’ve seen entire machine rooms added with no PHA review because the facility felt that the change was a “minor” change. The reality of implementing the IIARs guidance was that people were deciding if a change was “minor” or “major” based on their gut feeling of the size/complexity of the change – They weren’t actually reviewing the PHA to make this determination. The IIAR scheme acted as a “shortcut” for many facilities as they tried to jam ever larger & more complex changes into the “minor” category.

Furthermore, we found that almost none of these poorly performed MOC procedures were being caught by the facility. Since one person was in charge of (and administering) the entire program, there was essentially NO oversight. Adding the PSSR at the end of the equipment / facility MOC procedure provided a degree of oversight.

Simplification: Removing the “minor” and “major” categories meant that all equipment / facility changes followed the same procedural steps. Each equipment / facility change now requires the “Responsible Person” to review the relevant PHA section(s). Please note that this is not a full-scale team-based exercise – it’s the “Responsible Person” reading through the relevant section(s) and making a determination based on their expertise. Obviously, as in all other cases, if the “Responsible Person” is encouraged to seek any operational or engineering expertise they might lack. If the PHA section(s) appears unaffected by the change, then that’s the end of the issue until the regularly scheduled PHA revalidation. If, however, the PHA section(s) appears to be affected, then they need to be revalidated by a team meeting the requirements of 1910.119(e) & 40CFR§68.75.

Also, added at this time were individual component PSSR sheets. That is, for each common type of equipment in an NH3 refrigeration system, a sheet was created that allowed you to quickly document the Pre-Startup Safety Review. These sheets covered various required PSI items as well as IIAR Bulletin 109 items that have been commonly requested and IIAR Bulletin 110 inspection & maintenance items. Since, this PSSR is required (by the Written Plan) for every equipment / facility change, they provide a oversight function as well as meeting the regulatory requirements.

—

All of these changes are made to improve the MOC & PSSR process.

To meet the requirements of the MOC element 1910.119(l)(2)(ii) you have to “assure that the following considerations are addressed prior to the change: …Impact of change on safety and health.” If you haven’t read this OSHA MOC guidance recently, I highly commend it to you:

An MOC procedure is required anytime a change per the requirements of 1910.119(l) is considered. An MOC procedure is a proactive management system tool used in part to determine if a change might result in safety and health impacts. OSHA’s MOC requirement is prospective.

The standard requires that an MOC procedure be completed, regardless of whether any safety and health impacts will actually be realized by the change. The intent is, in part, to have the employer analyze any potential safety and health impacts of a change prior to its implementation. Even if the employer rightly concludes there would be no safety and health impacts related to a change, 1910.119(l)(1) still requires the employer to conduct the MOC procedure.

The MOC requirements are important because many large incidents have occurred in the past when changes have been made and the employer either did not consider the safety and health impacts of the change, or did not appreciate (wrongly concluded) the potential consequences of the change before it was too late. Therefore, it is not only required, but important that the employer conducts an MOC procedure on each change, even those changes the employer believes will have no safety or health impacts. (OSHA, Refinery PSM NEP, 2007)

It is the word prospective in the above text that is most important. You can think of the dictionary-like definition of “a study that starts with the current condition and follows it into the future.” You could also think of those men and women who panned for gold in the western territories of the US during the 19th century.  Like them, you are looking through a lot of mundane things to find the rare oddity – that unique nugget – that can cause trouble.  In an MOC the nugget is a hazard that needs a safeguard – either a new one, or one you already have but haven’t yet applied to the discovered hazard.

Where do you document the hazards you’ve found and the safeguards you’ve put in place? The Process Hazard Analysis!

2017 SOP Template Updates

January 9, 2017 /

The SOP reference element guideline and RESOP/ROSOP reference  templates have been updated for 2017. The changes are basically broken into two groups: Continuous Improvement and IIAR 7.

Continuous Improvement: As always, there are a lot of little change suggestions that have been built up over time that were expressed in different templates in slightly different ways. Here are some of the change highlights in this section:

  • Section breaks are all now 3pt and merged into a single cell.
  • Stray CG Times font text changed to the default Book Antiqua that is used everywhere else.
  • All RESOPs (and Appropriate ROSOPs) follow this section order:
    1. Normal Startup
    2. Monitor Normal Operations
    3. Emergency Operations
    4. Emergency Shutdown
    5. Manual Shutdown and Isolation
    6. Maintenance Procedure(s) such as Oil Draining and schedules MI tasks.
  • Startup steps were re-organized and harmonized between equipment types.
  • HOA/LOTO steps made more explicit and consistent.
  • Emergency Shutdown section easier to follow and harmonized between equipment types.
  • Added text referencing the Incident Investigation element in the Emergency Shutdown section.
  • Shutdown section now starts with an option to just STOP the unit using the control computer/panel and then provides steps to Isolate and pump it down.
  • Harmonized Operating Limits, Consequences of Deviation and Steps Required to Correct or Avoid Deviation between equipment types. These sections were also harmonized with consistent BOLDing of the relevant variable between the sections as appropriate.

IIAR 7: I have long bypassed IIAR 7 “Developing Operating Procedures for Closed-Circuit Ammonia Mechanical Refrigerating Systems,” preferring to use the CCPS “Guidelines for Writing Effective Operating and Maintenance Procedures.” While my reference templates still use the CCPS as their basis, I felt it necessary to perform a Gap-Analysis between the templates I’ve been using (and continuously improving) for over a decade and the requirements in IIAR 7-2013. This is especially important because the International Machine Code (IMC) has been updated to point to IIAR 2-2014 (Safe Design of Closed-Circuit Ammonia Refrigeration Systems) which references IIAR 7-2013. While I am still not calling IIAR7 RAGAGEP in my PSM programs, I wanted to ensure that the PSM program SOP(s) were compliant with it. While there were no significant changes necessary to make the templates more compliant with IIAR 7, some changes were necessary. Here’s what changes were required for IIAR 7 compliance:

  • Explicit reference to control alarms during Start-up
  • Updated checks during Normal Operations to ensure coverage of all the items listed in IIAR 7
  • Include Supervisory Notification during Shutdowns

For those of you who use these reference templates, they are available in the Google Share in a directory called “IIAR 7 Mods.” After a few months of trials and minor revisions, these templates will replace the existing templates in the main directory. The old templates will be rendered obsolete and moved to the 0bsolete directory.

If you have existing SOPs using the 2016 (or earlier) versions of the template, you will want to compare the new templates with your existing implementation. Please note: These new templates will be the basis for ALL future template modifications / updates.

Below is a list of ALL the changes made to the SOP template section.

  • SOP Guidelines
    • Modified Implementation Policy: Operating Phases: Temporary Operation to include an explanation that a Temporary Operation SOP would require an MOC which would involve supervisory oversight due to the requirements of IIAR 7 6.2.3.1(a), 6.3.3.1(a), 6.5.3.1(a), 6.6.3.1(a), 6.7.3.1(a) & 6.8.3.1(a).
  • Compressor RESOP Template
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.2.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.2.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.2.4 & 6.2.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
  • Condenser RESOP Template
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.3.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.3.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.3.4 & 6.3.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
  • Air Unit RESOP Template
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.4.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.4.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.4.4 & 6.4.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
  • Vessel RESOP Template
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.5.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.5.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.5.4 & 6.5.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
  • Recirculating Vessel RESOP Template
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.5.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.5.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.5.4 & 6.5.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
    • Added reminder about documenting oil drained during the oil draining procedural section.
  • Heat Exchanger RESOP Template
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.4.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.4.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.4.4 & 6.4.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
  • Autopurger RESOP Template(s)
    • Re-ordered startup steps to optimize efficiency
    • Added explicit reference to control alarms during Start-up due to the requirements of IIAR 7 6.4.1.1(g)
    • Modified Monitor Normal Operations sections to include explicit checks for all appropriate items in section of IIAR 7 6.4.2.1
    • Optimized HOA / LOTO call-out Made more explicit LOTO call-outs in the Manual Shutdown section.
    • Optimized lead-in language to Manual Shutdown section and closure of Emergency Shutdown section to include Supervisory notification required under of IIAR 7 6.4.4 & 6.4.5.1. Manual Shutdown now starts with an option to just STOP the unit and then offers steps to pump it down.
    • Optimized Emergency Shutdown section to make it easier to follow. Added an explicit requirement to notify supervisory personnel so they can evaluate the need for an Incident Investigation.
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text.
  • Overall System Operation ROSOP 101 Template
    • Updated the Safety & Health section to use more of the IIAR example wording.
  • NH3Vent ROSOP Template
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Updated Emergency Operations & Equipment Information section to standardize use of capitalization and bold text. A nearly complete rewrite of the section as well.
  • Car-Seal ROSOP Template
    • Updated the Safety & Health section to use more of the IIAR example wording.
  • Line Opening (LEO) ROSOP Template
    • Updated the Safety & Health section to use more of the IIAR example wording.
    • Removed – Non-Permit version of the ROSOP. Still available in 0bsolete archive.
  • Lockout/Tagout (LOTO) ROSOP Template
    • Updated the Safety & Health section to use more of the IIAR example wording.
  • Personal Protective Equipment (PPE) ROSOP Template
    • Updated the Safety & Health section to use more of the IIAR example wording.
  • Quality Assurance (QA) ROSOP Template
    • Updated the Safety & Health section to use more of the IIAR example wording.

Yes, there are a LOT of changes! If you want any assistance or clarification on any of these changes, feel free to contact me.

 

 

APR’s aren’t Magic

October 17, 2016 /

When I see people writing “Have a Full-Face APR (Air Purifying Respirator) nearby, within arm’s reach” in their Line/Equipment Opening (aka Line Break) procedures, my blood-pressure shoots through the roof. Yes, I know I am a rather excitable guy by nature, but there is a legitimate reason for my anger here. 

This incident narrative is why: 

 It is believed the oil drain valve was initially clogged as the employee opened it a full three turns before any ammonia came out. When liquid exited the valve and struck the employee he fell face first on concrete in hallway.   “Convulsions” were observed by other employees and the operator was unable to self-rescue due to lung spasms. The other employees had no access to PPE and could not assist the victim. 

Would a Full-Face APR within “arm’s reach” have been useful to that employee AFTER he was struck in the face with liquid ammonia? 

NO. IT WOULD NOT.

With NO protection, that operator was essentially doomed the second the NH3 left the pipe and struck him.

PPE stands for Personal Protective Equipment, not Potentially Protective Equipment.

PPE isn’t some sort of magic relic that provides protection while you are within a certain radius of its location. It works when – and ONLY when – you use it properly. This same foolish thinking that allows people to require APR’s “nearby” could be applied to seat-belts with about the same effectiveness: “Well, no he wasn’t wearing the seat-belt during the accident. Funny thing: the darned seat-belt was right there next to him and he still went out the window when the car hit the tree.”

Now, imagine instead that the operator in that incident narrative was wearing a Full-Face APR. While Full-Face APR’s aren’t designed for liquid exposure, would he have survived if he were wearing one? Almost certainly, YES. Certainly his odds would have improved astronomically. He may well have suffered severe burns, but it is very likely that the Full-Face APR would have afforded him enough protection so that he would have been able to evacuate himself from the area and seek a safety shower to minimize the damage to his skin.

Please, THINK about your policies and REQUIRE that Full-Face APR’s are worn during ALL Line & Equipment openings.

102417 Update: Here’s a picture that perfectly illustrates the uselessness of having PPE “nearby”…

When does a Car-Seal program make sense for Industrial Ammonia Refrigeration systems?

September 9, 2016 /

First off: What is a Car-Seal program and what does it do? 

A Car-Seal program is designed, implemented and managed to ensure that safety-critical valves within the covered process are maintained in their safety-critical position / setting during normal system operation. If the position / setting of a safety-critical valve is to be changed, it provides a procedure that functions as an administrative control to make this change safely.

Car-Sealing a valve OPEN or CLOSED is used ONLY if opening or closing that valve during normal operation could result in a Severe Safety Incident. Car-Sealed valves are usually designated on the P&ID’s as Car-Sealed OPEN (CSO) and Car-Sealed CLOSED (CSC), and are physically identified as Car-Sealed in its designated position / setting.

In order to more readily identify the location of the intended Car-Seals in the field, as well as the NORMALLY SAFE valve position / setting, the tags will be secured to the valve using COLOR CODED PLASTIC TIE STRAPS.

carseal

To put it bluntly: Car-Seals are placed on valves where REALLY bad things can happen if you move them from their normal (Safety Critical) position without taking precautions!

Where are they used in Industrial Ammonia Refrigeration Systems? 

You should already have at least two Administrative Controls (safeguards) meant to minimize the hazard of opening and closing the wrong valves: Written SOPs and Trained Operators. The Car-Seal program is meant to add a third layer of protection on top of those two when changing the position of the valve could reasonably result in a Severe Safety Incident.

Severe Safety Incident – shall mean any incident which could result in any one or more of the following results:

  • An OSHA Recordable accident, fatality, one or more employees/contractors hospitalized
  • Any fire requiring the use of more than one (1) portable extinguisher or one wheeled unit to completely extinguish
  • Any environmental incident involving a regulated material which violates any of our permits or requires disposal of a hazardous waste
  • Any incident which activates or disables a pressure safety device.
  • Any event which had the clear potential for sudden loss of human life, either within the plant or beyond the fence line, which would result directly from a chemical release, fire or other safety-related incident
  • Any event which required an offsite notification of any type agency (fire, LEPC, EPA, OSHA, County Officials, City Officials)
  • Any event in which the site alarm system activates or is disabled (excluding false alarms and tests)

While the decision as to which situations could reasonably result in a Severe Safety Incident are best left to the PHA team, the following are common situations where they have been used:

  • On the CD Isolation Valve of a Condenser Coil
  • On the Inlet or Outlet Isolation Valve of a Thermosyphon Heat Exchanger
  • On any liquid cooling Heat Exchanger without a relief device*
  • Where a shutoff valve is placed before or after a relief device*
  • At Isolation Valves for dead-end or Future Expansion legs.

* A relief device in this case means a device to relieve excess pressure. While relief valves are common solutions, other examples include checkvalves, pressure-relieving regulators, EPCS solenoids, etc.

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