PHA Synergy: How to get more out of the PHA process

According to 1910.119(e) and 40CFR68.67(a) the purpose of a PHA is to “…identify, evaluate, and control the hazards involved in the process.” Since the mid-90’s the refrigeration industry has done this mainly through the IIAR’s “What-If” methodology as suggested in their Compliance Guidelines materials.

There have been many revisions of this material over the years, but they all have the same thing in common as you use them: You can see how each question / item:

  • Poses a failure scenario (sort of a lesson someone else has already learned)
  • Prods you to solve the issue through an existing RAGAGEP

For example, a question might ask something like “What if plugs, caps, or blind flanges are missing on purge or drain valves?” This should prod you to recall that both IIAR 2 and IIAR 4 require that these things be plugged, capped, etc. This should also prod you to ask how you are addressing this requirement in your Process Safety Program.

The issue we always came across is that you must KNOW or MEMORIZE what the RAGAGEP says in a very complete way, or you miss the connection between the “What If” scenario and the RAGAGEP. This is nearly impossible because it seems like RAGAGEP is multiplying at an alarming rate. Furthermore, this (at least two day) process often feels like a futile effort at figuring out what the “What-If” scenario questions are really getting at.

To improve this years ago, I started adding two things to the IIAR standard questions:

  1. References to the IIAR standards where appropriate. (For example, in our plug question, reference IIAR 2-2021 13.3.2.6 & IIAR 4-2020 10.4.5.4)
  2. Explicit checklists that allow you to compare your system to appropriate RAGAGEP outside of the “What If” scenarios.

 

It’s very easy to lose sight of evolving RAGAGEP over time. These checklists allow you to perform a forensic examination of your system compared to current RAGAGEP. In addition to the issue of improving RAGAGEP compliance, we also face other challenges.

  1. It is common to show up to perform a PHA and find the client lacks critical Process Safety Information and PSM elements & procedures making a compliant PHA extremely difficult or impossible.
  2. Incident Investigations are often in a state of disarray or incomplete making their inclusion in the PHA difficult at best, and almost meaningless at worst.
  3. IIAR 9 now requires an evaluation against its minimum requirements for all NH3 refrigeration systems at least every five years.
  4. In some regions the EPA has an almost absurd number of questions they “like” to see in your Facility Siting sections.
  5. The Emergency Action Plan is a critical safeguard in your program, and it is usually missing some basic items that aren’t apparent until you try and use it in an emergency.
  6. Finally, the IIAR has standards on Installation, Commissioning, and Decommissioning that are often overlooked.

 

This again leads us back to checklists. I created them for basic PSI & PSM items, Incident Investigations, IIAR 9, Facility Siting, EAP, IIAR 4, IIAR 6, and IIAR 8. Here’s what that looks like:

As you can see, that’s fairly comprehensive, but it’s also a lot more work! To adjust to all this, we usually perform PHA’s in a two-step process.

Step 1: Weeks in advance, we give the client the relevant checklists and have them fill them out to the best of their ability.

Step 2*: Once we’re on-site, we go over the checklists they’ve worked on to answer any questions, address discrepancies, etc. THEN we move on to the “What If” scenarios.

* Of course, if the client wants, we can always book another two or three days of our time helping them on-site with Step 1.

 

The result of this longer, more comprehensive process is:

  • A nearly point-by-point check of the facility (and their Process Safety program) against common RAGAGEP from a HAZARD perspective rather than a compliance one.
  • A much better understanding of the “What If” scenario questions when we get to them after the checklists.
  • Cleaner, more systemic recommendations that point to specific hazards and the RAGAGEP that most effectively addresses them.
  • At the end of the PHA process, facility team members have a much clearer understanding of where the requirements and recommendations are coming from.

You can learn more about our PHA offerings here. Email or call us today to have RC&E assist you with all your PSM/RM Program needs! info@RCE-Chill.com    (888) 357-COOL (2665)

Happy 7/17!

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 to your mentors
  • Become a mentor

 

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!

U.S. Department of Labor Announces Annual Adjustments to OSHA Civil Penalties

WASHINGTON, DC – The U.S. Department of Labor has announced adjustments to Occupational Safety and Health Administration (OSHA) civil penalty amounts based on cost-of-living adjustments for 2021.

In 2015, Congress passed the Federal Civil Penalties Inflation Adjustment Act Improvements Act to advance the effectiveness of civil monetary penalties and to maintain their deterrent effect. Under the Act, agencies are required to publish “catch-up” rules that adjust the level of civil monetary penalties, and make subsequent annual adjustments for inflation no later than January 15 of each year.

OSHA’s maximum penalties for serious and other-than-serious violations will increase from $13,494 per violation to $13,653 per violation. The maximum penalty for willful or repeated violations will increase from $134,937 per violation to $136,532 per violation.

Visit the OSHA Penalties page for more information. The Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2021 final rule is effective January 15, 2021, and the increased penalty levels apply to any penalties assessed after January 15, 2021.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.

The mission of the Department of Labor is to foster, promote, and develop the welfare of the wage earners, job seekers, and retirees of the United States; improve working conditions; advance opportunities for profitable employment; and assure work-related benefits and rights.

While I’m sure the next few years are going to be very interesting from a regulatory standpoint, this is just he annual change to reflect inflation.

Link to full press release.

The 2020 Christmas Update

Merry Christmas to our Ammonia Refrigeration Process Safety community!

 

Well, this year has been interesting, eh? The hits keep coming it seems, and it was no different to those of us in the Process Safety field. Behind the scenes, we’ve been working on a fairly major set of improvements to the PSM system. Originally scheduled for August, we’ve finally managed to push it across the finish line just in time for the Holidays!

Significant improvements were made to the core of the system (The SOPs and ITPMRs) through an unprecedented amount of end-user feedback. Remember, this system relies on the feedback of operators, technicians, service personnel, and Process Safety professionals to improve.

All updated documents have the 122520 date-code, but here’s a run-down:

  • Minor updates to definitions file
  • All element written plans:
    • Where it was appropriate, did a little harmonization with the newest IIAR Process Safety Management & Risk Management Program templates. (There isn’t really anything they cover we don’t, but there are some places we harmonized the phrasing where we cover the same ground)
    • Ensured all element Written Plans refer to the ROSOP QA – Document Quality Control section in the Document Management
    • Minor editing / formatting improvements
  • Minor change to Operator Training element to ensure that Initial Training on Incident Investigation includes a review of recent and routinely recurring incidents.
  • Improvements to the II element written plan’s “Incident Investigation Process Flowchart”
  • SOPs
    • Minor changes to the Implementation Policy: Review and Annual Certification to harmonize with the IIAR guidance
    • Annual SOP Certification letter improved to correlate with the SOP element Written Plan more closely
    • The SOP element Written Plan Implementation Policy: SOP Authoring / Generation section now provides “Best Practices” standard language for warnings, step comments, step instructions, etc.
    • ALL SOP Templates now:
      • Use the “Best Practices” language.
      • Include better language tying them to the ITPMRs
      • Reference ROSOP-PPE in the Safety considerations section
      • Additional Equipment Considerations added to harmonize with the IIAR guidance
    • ROSOP PPE slightly improved with reference to LEO
    • ROSOP LOTO improved with improved language from end-users
    • Minor updates to ROSOP QA – Document Quality Control section.
    • ROSOP LEO streamlined and simplified with a good amount of end-user feedback
    • New ROSOP ITPM based on significant end-user operator input and feedback (See MI section below)
  • MI / ITPMRs
    • All ITPMRs now provided as PDF forms as well as Word documents
    • All ITPMRs have improved references including to the new ROSOP ITPM
    • All ITPMRs now have a space to record task hours
    • All frequency ITPMRs are now in a single document. For example, previously we would have a 30-day, 90-day, and 365-day ITPMR for condensers. Now we have a single ITPMR for condensers with all the items and you simply use the applicable sections. This allowed each step in the ITPMRs to have its own unique step code. This is important because….
    • A new SOP was created called ROSOP ITPM which includes additional information for less-skilled operators and technicians. This new ROSOP also is used as a repository of best-practices and collected knowledge from field operators. Relevant guidance from applicable IIAR standards was also included directly in the SOP where we thought it useful to those performing the MI work. A group of contractor service technicians and end-user operators contributed to the creation of this SOP and We FULLY expect this SOP to grow and improve as we get even more field use and operator feedback.

 

To implement:

  • Written Plans: Follow the Implementation Policy: Managing Procedure / Document Changes. These should be straight-forward.
  • Definitions file: Replace with the new one
    1. For the new PPE and LOTO templates, either adopt them as-is or incorporate their changes to your existing PPE & LEO SOPs
    2. For all your equipment SOPs, consider updating them to the new language during your next scheduled revision / team review.
    3. For the NEW ROSOP-ITPM and PSSRs see the MI section below
  • MI: Replace the existing ITPMRs with the new ones, providing training that when the CMMS (or other scheduling system) calls for a frequency based ITPMR, just use the equipment specific ITPMR and fill it out to the appropriate frequency.
  • Provide training on the new ROSOP ITPM. Please collect feedback for improvements so we can all improve its performance.

Updated IIAR 4-2020 and IIAR 8-2020 standards released

IIAR 4-2020 Installation of Closed-Circuit Ammonia Refrigeration Systems and IIAR 8-2020 Decommissioning of Closed-Circuit Ammonia Refrigeration Systems have been released by the IIAR and are now available for purchase on their website. IIAR 8 didn’t change much, but this was a very significant change to the existing IIAR 4 standard.

In SHORT, here’s what you need to know as an end-user:

  1. For current/future projects that involve the installation, startup, and commissioning of new equipment, use the “IIAR 4 APP-B Checklist Tracking Log Template” to manage adherence to IIAR 4 before, during, and after the installation. Once this tracking log has been completed, you can document the final status in the PHA .ISC.APPB section of the related project PHA. (The tracking log is in \PHA\PHA Study Template\Optional Resources\)
  2. Ensure future PHA’s (including project PHA’s) comply with the requirements of IIAR 4 by using the existing equipment specific .ISC section and the new .ISC.C checklist section.

 

The long version follows…
Continue reading

How to respond to a Compliance Audit Report

Both PSM and RMP require a 3-year audit to “verify that the procedures and practices developed under the standard are adequate and are being followed.” While it is not required, this Compliance Audit is traditionally done through a 3rd party. A common failing I see in this element is end-users not understanding what to do with the Compliance Audit once they’ve received it. What follows are my thoughts on best-practices once you’ve received the Compliance Audit report.

  • Verify the Report
  • Certify the Report
  • Address the Findings / Recommendations
    1. Assess validity
    2. Decide on a solution to address valid recommendations
    3. Implement the solution including any needed interim solutions
    4. Document the resolution as closed

 

Verify the Report

You will want to ensure the report meets the requirements of the PSM/RMP rules as well as your internal Compliance Audit element Written Plan. First thing to do is to read through the report and any findings / recommendations to familiarize yourself with it. Your report may look different than the ones I deliver, but mine have five main parts:

  • An introduction letter describing the audit methodology and the report’s format
  • Closing meeting notes discussing highlights of the report and next steps.
  • An Audit Certification Page (discussed in the next section)
  • Statement of Qualifications: Qualifications of Company and PHA Facilitator / Compliance Auditor, Conflict of Interest Statement & Disclosure. This is basically a written answer to common “Who did this audit and why should we trust them” questions.
  • Compliance Audit worksheets & Findings / Recommendations

Once you understand the format of the report, decide if it met the goals of a Compliance Audit. I use the 3-levels of compliance as my performance basis.

Once you’ve established that the Compliance Audit report meets this performance basis, make sure it is:

  • Complete
  • Free of any copy-paste errors
  • Lacking any blank spaces / questions

If you have any questions or concerns, work with your auditor to address them at this stage, because once we go to the next step, this report is “set in stone.”

 

Certify the Report

Both PSM and RMP require that the employer/owner/operator certify the Compliance Audit report. I include a letter to be dated and signed. This step is often missed but it’s a very simple thing. You are not certifying that the report is 100% accurate, found every single thing wrong, etc. All you are certifying is that “you have evaluated compliance…to verify that the procedures and practices developed under the standard are adequate and are being followed.” In some sense, you’re really certifying that this collection of documents is your Compliance Audit, that you have received it, and that you believe it to be accurate.

 

Address the Findings /Recommendations

Each non-compliance finding will require some sort of action on your part. To assist in this endeavor, I personally rate the findings on a 4-level scale.

A simpler explanation of that rating system might be:

Green: All Good.

Yellow: It’s good, but there might be a better way.

Orange: This is wrong and can get you fined bur probably won’t get anyone hurt in the short-term.

Red: This is wrong and can get someone hurt or even killed.

Below is the flowchart from our model PSM/RMP program on dealing with recommendations. Please see this longer post on the subject for more information. Properly Addressing PSM / RMP Findings & Recommendations

Recommendations will be considered “addressed” when a plan has been put in place to address them. In some cases, a recommendation will not be accepted. OSHA considers an employer to have resolved recommendations when the employer has either adopted the recommendations or justifiably declined to do so. According to OSHA, an employer can justifiably decline to adopt a recommendation where it can document that:

  • The recommendation contains material factual errors;
  • The recommendation is not necessary to protect the health of employees or contractors, the public or the environment;
  • An alternative measure would provide a sufficient level of protection; or,
  • The recommendation is not feasible.

Whether accepting or rejecting a recommendation, it is important that you document your reasoning for doing so and any progress you are making, or have made. In our system we rely on an Implementation Policy called “Resolution of Recommendation” to do this. Below is an example of a recommendation that was tracked to resolution. Note that since it is now complete, they have shaded it green.

Conclusion: While it’s time consuming and labor-intensive, dealing with Compliance Audit recommendations is a fairly straight-forward task. As always, feel free to Contact Us if you have any questions, and check out our Compliance Audit section if you would like us to perform your next Compliance Audit.

Note: Nearly everything in this article is equally true for reports and recommendations from PHA’s, independent Mechanical Integrity Audits, etc.

IIAR 2 2020/2021 Public Review #2

The IIAR has just announced a Public Review of their IIAR 2 standard. IIAR 2 is the “Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems” so it’s worth reviewing. 

September 11, 2020
To: IIAR Members
Re: Second (2nd) Public Review of Standard BSR/IIAR 2-202x, Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems.
A second (2nd) public review of draft standard BSR/IIAR 2-202x, Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems is now open. The International Institute of Ammonia Refrigeration (IIAR) invites you to make comments on the draft standard. Substantive changes resulting from this public review will also be provided for comment in a future public review if necessary.

BSR/IIAR 2-202x specifies the minimum safety criteria for design of closed-circuit ammonia refrigeration systems. It presupposes that the persons who use the document have a working knowledge of the functionality of ammonia refrigerating system(s) and basic ammonia refrigerating practices and principles. This standard is intended for those who develop, define, implement and/or review the design of ammonia refrigeration systems. This standard shall apply only to closed-circuit refrigeration systems utilizing ammonia as the refrigerant. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes) where provisions in these may take precedence.

IIAR has designated the revised standard as BSR/IIAR 2-202x. Upon approval by the ANSI Board of Standards Review, the standard will receive a different name that reflects this approval date.

We invite you to participate in the second (2nd) public review of BSR/IIAR 2-202x. IIAR will use the American National Standards Institute (ANSI) procedures to develop evidence of consensus among affected parties. ANSI’s role in the revision process is to establish and enforce standards of openness, balance, due process and harmonization with other American and International Standards. IIAR is the ANSI-accredited standards developer for BSR/IIAR 2-202x, and is responsible for the technical content of the standard.

This site includes links to the following attachments:

The 45-day public review period will be from September 11, 2020 to October 26th, 2020. Comments are due no later than October 26th, 2020.

Thank you for your interest in the public review of BSR/IIAR 2-202x, Safety Standard for Design of Closed-Circuit Ammonia Refrigeration Systems.

Make your voices heard and comment to the IIAR! 

Below is a quick review of the significant suggested changes and my thoughts on them. 

1.3.3) Now requires “alternative means and methods” to be approved by a designed that is a licenced engineering professional. – This was common practice and helps you build a defensible case. 

2) Definitions. Added a definition of car-seal. I’m happy the IIAR has finally acknowledged this industry practice!

3.3) Moved a reference to IIAR 7 on SOPs to the Informative appendix. Not sure this matters much as IIAR 2 still refers to IIAR 6 which references IIAR 7. 

5.5.3) Saturation Pressures and Minimum Design Pressure. – They seem to have fixed the weird situation where your calculated low-side pressure could be higher than your minimum high-side pressure. 

5.8) Clarified that purging piping shall be compatible with NH3. This was requirement always in there, you just had to bounce around the standard to find it. 

5.11.4) Seems to add a new explicit requirement to document “the basis for the support design including the anticipated loads, demonstration that the support design is adequate for the anticipated loads, and that the supports meet or exceed the equipment manufacturer’s recommendations”

5.12.4.2) Clarifies that accessibility to “isolation valves identified as being part of the system emergency shutdown procedure” must be provided for people in emergency response PPE. 

5.14) Removed wind indicators as being required by IIAR 2

5.14.1) System signage requirements to reference “maximum intended inventory”, remove the quantity of oil requirement, and replace test pressures with design pressures. – That “maximum intended inventory” is going to cause a ton of confusion when the sign says the “maximum intended inventory” is 20,000lbs but the actual inventory documentation shows 17,500lbs. 

5.14.3) Changes the requirement for Emergency Shutoff Valve Identification from “uniquely identified” (which you could meet with valve tags) to “uniquely identified as emergency shutoff valves” both on the valves themselves and on the system drawings. This is going to be a major change for most people. I don’t think this change is worth the trouble it will cause. 

6.10.2) New requirement that “Machinery room doors shall open with the use of only the panic hardware and shall not require the use of other hardware or switches to exit the room.” which was a pet-peeve of mine. 

6.12.1) Requires the E-stop to be “manually reset” 

6.12.2) Removes the “protected from inadvertent operation” requirement for ventilation switches

6.13) Essentially this section strongly advocates for 2 NH3 detectors in the machinery room but does provide provisions for only 1.

6.13.2.3) Now requires audible alarms to be “manually reset by a switch located in the machinery room or alternatively in an area remote from the machinery room.” – This will be a significant control change for most people.

6.14.7.6) New language “A means of proving emergency airflow shall be provided. Failure to prove airflow when the emergency ventilation fans are energized shall provide notice to a monitored location. Devices that can be used to prove emergency airflow include, but are not limited to: 1) pressure differential switches 2) sail switches 3) current monitors. ” – This reflects what most people are doing anyway. 

7.2.5) Stronger language: “Protection of Equipment from Physical Damage. Where ammonia equipment is installed in a location subject to physical damage from powered vehicles normally operating in the area, guarding or barricading shall be provided.”

15.1.2) Allows car-seals downstream of relief valves that relieve internal to the system. – This has been the practice for years, so it’s nice that the IIAR has finally acknowledged it. 

15.2.5) Removes the exception “The vapor relief connection on an oil drain pot and similar applications shall be located at the highest point on the vessel.”

15.2.6) New requirement “Pressure relief devices intended for liquid pressure relief shall be connected below the anticipated liquid ammonia level and shall discharge internal to the system. “

15.2.9.1) New language “The employee of that device manufacturer or company holding a certification who last set and calibrated the pressure relief device shall seal the valve with a car seal.” – Calling it a car-seal is going to cause a ton of confusion here. This language should revert to the old language as just being sealed. 

15.4.6) Stronger language added here “Liquids and other refrigerants shall not be vented into a common relief piping system used to convey ammonia vapor.”

15.5) They changed the formulas for relief discharge piping. According to our engineering department, it’s mostly semantics and not substantive.

15.6.4) I believe this new wording just states what was already required by other codes/standards “15.6.4 Liquid Overpressure Protection required. Relief valves used for liquid pressure protection of vessels and equipment constructed in accordance with the ASME B&PV code are required to be constructed and marked in accordance with the ASME B&PV Code.”

15.6.6) New section on “Pressure Vessels and Equipment with Non-Volatile Liquid” which we are taking to mean Oil Pots and the like. This allows isolation of the relief protection during pump-down. Again, this has been the practice for years, so it’s nice that the IIAR has finally acknowledged it. 

17.2.1) Power supply section reworded to no longer require separate power circuit for the NH3 detection. 

17.3) Adds two new RAGAGEPs for NH3 detection design and testing “UL-61010-1 Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use or ANSI/ISA 92.00.01 Performance requirements for Toxic Gas Detectors.” I’ve reached out to my NH3 detector contacts and will follow-up with a separate post on the implications of these requirements. 

17.7.1) Level 1 detection requirements revert to pre-PR1 

What we can learn from the tragedy in Beirut, Lebanon?

“Smart people learn from their mistakes. Wise people learn from the mistakes of others.”

Or, in PSM terms: Incident Investigation is how you become smart. Process Hazard Analysis is how you become wise.

Yesterday, a horrific explosion occurred in the port of Beirut, Lebanon. This morning it is being reporting that over 100 are dead, over 4,000 are injured, and up to 300,000 are homeless. Estimates of the economic damage have been as high as five billion dollars. 

Beirut, Lebanon 080420

Beirut, Lebanon Explosion 08/04/20

It is believed that the explosion was the result of 2,750 tons of ammonium nitrate stored at the port. The authorities will now have to try and piece together what happened to see what they can learn from this incident.

Beirut, Lebanon 080420

Beirut, Lebanon Explosion Aftermath 08/04/20

In PSM terms, this is where we implement the Incident Investigation element. Refer back to that earlier quote, “Incident Investigation is how you become smart.” One of my first mentors put it another way: “Wisdom is healed pain.” It is right and proper that we learn from the mistakes we make, but there is a better way: Learn from the mistakes of others so you don’t repeat them!

Al Jazeera is reporting that the chemical storage was known about for seven years, and while the port authorities asked for assistance in dealing with the dangerous situation SIX TIMES, they did not receive a response. It appears that the authorities in Beirut had the information they needed to KNOW they had a hazards to address for many years. 

The dangers of Ammonium Nitrate explosion are WELL KNOWN.  Check out this older article on the events in West, Texas – or check out the pictures I took there after the explosion. (Note, according to the Al Jazeera timeline, the improper storage of this chemical in Lebanon began right around the time of this incident in America.)

West Texas 2013

Ammonia Nitrate explosion damage in West, Texas (2013)

A proper PHA prevents incidents. In the PHA process, we Identify hazards, Evaluate those hazards, and then Control those hazards.

A timely Process Hazard Analysis would have shown OBVIOUS problems with Facility Siting, RAGAGEP compliance, and equipment / facility suitability. It appears that in Beirut, the port officials informally identified at least some of the hazards, and to some degree they analyzed them. Those responsible in Beirut had AMPLE opportunity to CONTROL the hazards but chose not to – for reasons we don’t yet know. 

Put another way, because they did not accept their responsibility to perform a Process Hazard Analysis, they now have to accept their somber duty to perform an Incident Investigation.

Incident Investigation is how you become smart. Process Hazard Analysis is how you become wise.

Are there any issues in your facility that you are aware of that you haven’t yet addressed? Consider this tragedy in Beirut as a reminder to take action on them. There’s no time like the present!

P.S. There are large Ammonia Nitrate stockpiles all over the world. When stored properly it is very, very safe. But storing it next to a fireworks warehouse in a vault that wasn’t designed for it is begging for a disaster.

 

— Update: The Times of Israel quotes Lebanese Prime Minister Hassan Diab as saying: “What happened today will not pass without accountability. Those responsible for this catastrophe will pay the price.” With respect, no, they won’t pay the price.

The people that died paid the price. The loved ones of the deceased, the people that were injured, and those who are now homeless are paying the price. The people responsible may pay a price, but it’s unlikely to be as severe as the one paid by those who had no part in the series of errors that lead to this catastrophe.

Happy 7/17!

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 to your mentors
  • Become a mentor

 

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 4 & IIAR 8 Public Review #2

The IIAR announced that two standards are up for their second public review. IIAR 4 Installation of Closed-Circuit Ammonia Refrigeration Systems and IIAR 8 Decommissioning of Closed-Circuit Ammonia Refrigeration Systems. 

My IIAR 4 2020 PR2 Comments and Notes

1.3.4 Installations without an AHJ

This section appears to be rewritten for clarity, but it also removes the requirements that “alternative shall be documented in the design documents and provided to the owner and the installer.” This will definitely become a problem down the road when end-users are asked to justify their apparent non-compliance without adequate documentation of the designers engineering rationale.

 

4.2 Supervisor of Installation (Installer Qualifications)

This section has been revised and adds a requirement that Installing Contractors provide documentation to the facility that they have the skills necessary to:

    • Receive, transport, and install refrigeration equipment, piping, and components.
    • Assemble a refrigeration system.
    • Not harm themselves, others, or damage the structure in which the equipment is to be installed

I imagine this will be handled by some sort of “Letter to File” from the contractor.

 

4.5 Welding of Pressure Containing Components (Repeated in 4.6)

This change requires the contractor to provide the Welding Performance Qualification Record (WPQRs) for the past six months rather than the previous requirement that they just verify the welder’s credentials were not expired. This is going to be challenge to contractors. End-users should aggressively soliciit this information if they expect it in a timely fashion.

 

4.8.6 now explicitly requires that insulated pipe be spaced to allow access for inspections / maintenance. This was always a good idea.

 

4.9.1 now requires complete thread engagement rather than “3 exposed threads”

 

6.2.1 removes “reasonably free of rust” and replaces it with “free of pitting.” Internally, you should probably stick with the old requirement.

 

6.3.5 no longer allows valves connecting to atmosphere to be “locked closed” as they must now be capped, plugged or blind flanged. I don’t know of anyone that allowed a valve open to atmosphere to be locked closed without a plug / cap so this isn’t much of a change in the field.

 

IIAR 4 Links

 

My IIAR 8 2020 PR2 Comments and Notes

Note: Please keep in mind that, according to IIAR 1, decommissioning is “The permanent deactivation of a closed-circuit refrigeration system or part thereof.”

4.6 Documentation

This section moved the suggested methods to the appendix where they belong. Well-implemented PSM programs will likely handle all this documentation as a matter-of-course through their existing MOC, PSSR & PHA policies.

 

4.10 Operating Procedures

This change ONLY affects procedures for decontamination, but it removes the requirement that such procedures comply with IIAR 7. Those procedures would still likely be judged under 1910.119(f). Whenever there is some grey area as to whether a procedure falls under 1910.119(f)(1-4) or 1910.119(j) it’s always wise to link back both. My preferred language is something along the lines of “This procedure must be used in conjunction with the equipment SOP which provides Important Safety, Health, Environmental and Equipment Considerations as well as Controls, Instrumentation, Safety Systems, Valve Designations, Operating Limits, Consequences of Deviation, Steps Required to Correct or Avoid Deviation and an Emergency Shutdown procedure.”

 

4.12.2 Training Records

They’ve reworded this section to require a “sign off sheet” to document that people “received” the training rather than using the PSM/RMP language that you document the “means used to verify” that they “understood” the training. IIAR 8 doesn’t over-ride the existing PSM/RMP requirements, so this has little impact.

 

5.2.3.3 removes the prohibition on “fuel burning appliances” and provides some bromides about conducting such work “safely.” Our template program will continue to prohibit this. While there are obviously situations – especially during decommissioning activities – that may warrant their use, we want to ensure that such activities are run through an MOC (or similar administrative control) before their use.

 

5.3.1.1 changes the requirement that you track chemicals to their ultimate disposal to one that you document that they’ve left the facility. This is sensible and welcome.

 

IIAR 8 links

 

If you have comments on the IIAR’s suggested changes, don’t forget to hit up the comment links above.

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