Author: Brian D. Chapin (page 2 of 9)

IIAR 7-2019 Update

It’s been coming for a while now and yesterday it became official:

Introducing: ANSI/IIAR 7-2019Developing Operating Procedures for Closed-Circuit Ammonia Refrigeration Systems

In 2013, the first issue of IIAR 7 replaced the operations information contained in IIAR Bulletin No. 110, Guidelines for Start-Up, Inspection, and Maintenance of Ammonia Mechanical Refrigerating Systems.

This standard was first approved as an American National Standard by the American National Standards Institute (ANSI) in August 2013. ANSI requires reaffirmation or revision for periodic maintenance requirements of existing standards every five years. Work began on periodic maintenance of this standard in February 2017 and was completed in April 2019.

This standard defines the minimum requirements for developing operating procedures for closed-circuit ammonia refrigeration systems. Informative Appendix A was added to provide explanatory information related to provisions in the standard.

 

A little over two years ago, the SOP templates were updated to include all the requirements of IIAR 7 2013. That was a pretty large undertaking, but if you already made those changes, it looks like you are in good shape! I’ve reviewed the new IIAR 7 and it turns out we only need to make one substantive change to programs using the current templates.

 

What’s the requirement / change? 

The 2013 version required a visual inspection of hoses when they were used. This was a pretty minor requirement. The newer version requires that procedures include “Steps to inspect hoses and fittings visually to make sure they are suitable for ammonia refrigeration service”  whenever you Transfer (such as in pump-down) or Charge ammonia. To address this issue, I’ve modified the ROSOP-LEO and Permit form to include an explicit check and a reference to the “ITPMR-AHT-365 – Ammonia Transfer Hose Annual ITPM Record” we recently added due to IIAR 6.

So, if you’ve already updated your system for IIAR 6 compliance, then all you need to do is update your LEO procedure and Permit. If you haven’t updated your system for IIAR 6 compliance, then you need to integrate the new ITPMR as well as make plans to address the entirety of IIAR 6.

Note: Overall the 2019 IIAR 7 is much simpler than the 2013  version. It’s moved a lot of stuff to informative appendices which removes most of my complaints about it. Unfortunately they renumbered* just about every single requirement in the standard. This meant I had to completely renumber / rewrite my standalone SOP audit template. The good news is that the IIAR7-2019 version of that audit was reduced from 110 pages to 87. Of those remaining 87 pages of questions, 60 pages are due to IIAR 7.

* This was not an attempt to drive me closer to insanity, but an attempt to harmonize numbering systems between all the IIAR standards. I know this because I actually asked the IIAR about this. Thankfully, Tony Lundell has a good sense of humor.

Using the Hierarchy of Controls as a tool for Incident Investigations

The issue: Poor Incident Investigations and how to improve them

Often members of the Incident Investigation team miss some fairly obvious opportunities to improve their process safety. One trick is to use the Hierarchy of Controls as a brainstorming tool when coming up with causes and recommendations.

 

What is the Hierarchy of Controls and How can I use it as a tool during Incident Investigations?

The premise of the Hierarchy of Controls is that while hazards can be controlled in various ways, certain types of controls are inherently better than others. The hazard controls in the hierarchy are, in order of decreasing effectiveness:

Let’s take an example of an Incident Investigation concerning an unexpected employee NH3 exposure during an oil drain. While you will have to address any unique issues relating to the incident, here are some questions that the Hierarchy of Controls can provide for any oil drain incident:

Elimination: Physically removing the hazard. For example, when analyzing the risk of a valve packing leak in a process room, moving that valve to the roof would eliminate the hazard from the production room. Elimination is usually considered the most effective hazard control.

Substitution: Replacing the hazard with something that does not produce a hazard or something that produces a much smaller hazard. A common example of this is removing the hazard of NH3 in product chillers areas with the use of a secondary refrigerant such as CO2 or Glycol. Note that in some instances this results in simply relocating a hazard to another area with lesser consequences.

Note: We usually combine these two methods because if we don’t, we tend to spend more time arguing whether or not a control is an elimination or a substitution.

  • Can we avoid, or reduce the frequency of, the oil drains? Better coalescers, higher minimum head pressure to reduce oil blow-by, installation of an oil still to minimize oil draining from the system, etc.
  • Can we eliminate / reduce the NH3 involved in the oil drain? Pumpout of the oil pot and re-pressurization with shop air, conversion to a gravity drain oil pot, lower pressure suction during pumpout, etc.

 

Engineering Controls: These controls do not eliminate hazards but tend to attempt to control them or give notice when the process is approaching an unsafe state. Examples include NH3 sensors, Interlocks, High-Level Floats, Pressure and Temperature transducers, etc.

  • Is the equipment properly configured for a safe oil drain? Oil pot, “Dead-Man” valve, safe access, easy egress routes, etc.
  • Can we improve the ventilation in the area? Portable fans, local exhaust ventilation, manual use of existing Machine Room fans, etc.
  • Can we improve the hazard awareness? Local / Personal NH3 detector rather than relying on a fixed detector, pressure gauge installed during the pump-down, etc.

 

Administrative Controls: These controls are changes in the way the work is performed on or around the process. Training, Procedures, Signs and Warning labels are all administrative controls.

  • Can we improve the SOP? Better steps to address the hazards, mandating more oversight, required use of PPE, more effective use of ventilation, etc.
  • Can we improve the training? Better understanding of the hazards, procedures, PPE, tools, etc.

 

Personal Protective Equipment: PPE such as gloves, respirators, etc. is generally considered the last resort of hazard control.

  • Can we improve the PPE available? Can we make certain PPE mandatory? Improved gloves, smocks, respirators, etc.

 

Using the Hierarchy of Controls can be a great brainstorming tool to help you look at your possible causes, and your possible corrections from some new angles.

The Five Stages of PSM Grief

How many times have you as a PSM manager had to present to operators or management some new understanding of the requirements of PSM? Maybe it’s a new IIAR standard, or some other RAGAGEP requirement.

Individuals don’t like to change. Organizations REALLY don’t like to change. There is always some resistance and many years ago, I noticed that it resembled the Kübler-Ross stages of grief that people go through when losing a loved one or being diagnosed with a terminal disease.

Here’s a humorous take on the stages of policy acceptance we deal with from our coworkers:

  • Denial: “There is no way I am doing that. We’ve been doing it this way for 25 years. They can’t be serious. You must have misunderstood the requirement.”
  • Anger: “You’re an idiot. Why are you putting us through this – this will never work. I’ll tell those OSHA/EPA/IIAR guys what for!”
  • Bargaining: “Fine, I’ll just pencil whip it and ignore the policy as soon as you turn your back. My buddy at another place says they just ignore this so we should too. It’s not like we’ll ever get caught anyway.”*
  • Depression: “They’re serious! We’re actually going to have to follow this new policy. This is insane! We’ll never have time to get our work done now.”
  • Acceptance: “You know. This isn’t as bad as I thought. On balance, it might actually be a little bit better than the old way.”

*Note: It’s possible to stop at this stage – and still be compliant – if you actually create an alternative means of addressing the issue that the new requirement does. It’s difficult to prove that your alternative solution is as safe or safer than the RAGAGEP, but it is possible. In most cases, it’s just easier to move on to Acceptance and implement the new RAGAGEP!

One Hazard, Multiple Attempts at Control

Given the catastrophic nature of the hazards associated with PSM, the interrelationship of the PSM elements work together as a safety net to help ensure that if the employer is deficient in one PSM element, the other elements if complied with would assist in preventing or mitigating a catastrophic incident. Consequently, the PSM standard requires the use of a one hazard-several abatement approach to ensure that PSM-related hazards are adequately controlled. (OSHA, CPL 2-2.45A, 1994)

 

The text above, from OSHA’s old PQV (Program Quality Verification) audit is critical to understanding a key concept of successful Process Safety: The more ways you attempt to control a hazard, the more likely you are to be successful.

Sometimes this concept is referred to as the “Swiss Cheese Model.” I’ll quote from Wikipedia:

It likens human systems to multiple slices of swiss cheese, stacked side by side, in which the risk of a threat becoming a reality is mitigated by the differing layers and types of defenses which are “layered” behind each other. Therefore, in theory, lapses and weaknesses in one defense do not allow a risk to materialize, since other defenses also exist, to prevent a single point of failure. The model was originally formally propounded by Dante Orlandella and James T. Reason of the University of Manchester, and has since gained widespread acceptance. It is sometimes called the cumulative act effect.

To understand how this works in a functioning program, I want to point out how we recently addressed a single hazard in our program to show how many different ways we attempted to control it.

 

The hazard

 In IIAR’s upcoming standard 6 “Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems” a hazard is identified and a prohibition is put in place to address that hazard:

 

5.6.3.4 Hot work such as the use of matches, lighters, sulfur sticks, torches, welding equipment, and similar portable devices shall be permitted except when charging is being performed and when oil or ammonia is being removed from the system.

 

The IIAR is recognizing that there is an increased likelihood of an Ammonia / Oil fire during charging operations and when oil / ammonia is being drained from the system. They are prohibiting Hot Work operations during these operations to remove potential ignition sources.

 

The Control(s)

You can make a (weak) case that simply referencing the RAGAGEP and inserting a single line in your Hot Work policy address the compliance requirement, but we’re going to need to do a lot more to make this prohibition a “real” thing in our actual operations.

 

Control Group #1: The Hot Work element

In the element Written Plan, we added two new “call-out’s” in the two places they are likely to be seen when planning Hot Work policies. First, in the section on Conducting Hot Work:

 

Second, in the section on Sulphur Stick use:

 

Third, in the Hot Work Permit itself, we modified the existing question on flammable atmospheres:

 

Control Group #2: The Operating & MI Procedures

All procedures that involve oil draining, ammonia charging and ammonia purging already point to the LEO (Line & Equipment Opening a.k.a. Line Break) written procedure. This makes our job a bit easier here, since we only have to modify our LEO rather than the dozens of procedures that might include this type of work.

We modified the traditional LEO “General Precautions section to place a check for Hot Work during an existing requirement to canvas the area for personnel that may be affected by the LEO:

 

In the more advanced, two-step “Pre-Plan and Permit” version of our LEO, we modified the “Pre-Plan Template” to include a warning:

 

In both versions of the LEO permit itself, we added an explicit check:

 

Closing Thoughts

This one small RAGAGEP change points to a single hazard – a hazard that we’re now trying to control in six different ways. Notice that we’ve made all these changes so they are popping up throughout the program:

  • In preparing policies for the associated work;
  • In the course of preparing for the work itself;
  • In the course of conducting the potentially hazardous operations.

This is critical because if we want to get the best “bang for our buck” in Process Safety, the safety portion has to be integrated into our actual processes on multiple levels.

Obviously, we’ll have to train on these changes to ensure that they’ll be effective. It’s quite possible that, after implementation, we’ll identify additional ways to prevent the hazard from being realized and will need to make further changes.

IIAR 6 – What do you need to know?

What is IIAR 6?

ANSI/IIAR 6-2019 is the IIARs’ new Standard for Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems. To quote the forward from the public review:

This is a new standard intended to replace IIAR Bulletin No. 108 Guidelines for: Water Contamination in Ammonia Refrigeration Systems, IIAR Bulletin No. 109 Guidelines for: IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System, IIAR Bulletin No. 110 Guidelines for: Start-Up, Inspection, and Maintenance of Ammonia Mechanical Refrigerating Systems, and IIAR Bulletin No. 116 Guidelines for: Avoiding Component Failure in Industrial Refrigeration Systems Caused by Abnormal Pressure or Shock. This new standard is intended to be a single source for the minimum requirements for ITM tasks for safe closed-circuit ammonia refrigeration systems.

Note: Design items pertaining to Bulletin No. 108 and Bulletin No. 116 are being considered to be incorporated in the next revision of IIAR 2, before these two bulletins are superseded.

When will it take effect?

Now that ANSI/IIAR 6-2019 has finished its Public Reviews, the end of this long journey is nearly over. Already approved by the IIAR Board of Directors  and ANSI, the new standard should be published around July 1st.

Once the new standard is officially published it comes into effect once YOU or the AHJ adopt it. Most model codes are expected to adopt it in their 2021 review cycles.

Why should I care about it now?

There are a few reasons:

  • The old combination of outdated and scattered bulletins was difficult to follow and wasn’t updated to deal properly with modern equipment. ANSI/IIAR 6-2019 has a more modern sensibility.
  • There’s really nothing in ANSI/IIAR 6-2019 you shouldn’t want to do – it’s all fairly sensible “good practice” advice.
  • There’s a slightly lower administrative / MI overhead following the new standard than the old bulletins.
  • I think – overall – that it’s easier to comply with ANSI/IIAR 6-2019 than the old combination of bulletins.

 

How would I go about ensuring compliance with IIAR 6?

You will have to thoroughly review ANSI/IIAR 6-2019 and perform a Gap Analysis between its requirements and your current PSM/RMP system. Pay special attention to:

  • Your Mechanical Integrity element, schedule, work orders (ITPMRs) and MI procedures.
  • Your SOPs to the extent that they deal with shutdowns, start-ups and turn-arounds.

  

What would such a Gap Analysis look like?

 If you are using my template system, the good news is that I’ve updated the ENTIRE system to be ANSI/IIAR 6-2019 compliant. Because this has been a LARGE project that’s taken a lot of time, all the new files have been given the same date code: 030219.. You can grab the updated templates on the Google Shared Drive. Some things like the Element Written Plans, ITPMRs are plug-and-play, but others like the MI-EL1, SOPs, etc. will have to be customized for your facility. If (when) you update your PSM/RMP system, don’t forget to implement your MOC procedure! Please note: ALL future template additions will include the ANSI/IIAR 6 compliant text that has been added.

Below is my list of implementation challenges, observations, and changes

 

Challenge #1: Section 5.5.1.3 Inspection & Test documentation

While I applaud the IIAR for pointing out the necessary requirements for a FUNCTIONALLY EFFECTIVE MI system, it’s a very real possibility that this section and its requirements will be interpreted to require this documentation IN THE MI system. That’s unrealistic for some of the information and experience has shown us that it’s likely unworkable in the field. Below is a table that shows the IIAR documentation requirements and how they are handled in the PSM system.

IIAR Cite

Requirement How it’s Handled
5.1.1.3.1 Date of the inspection or test. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.2 Name of the individual or individuals that performed the inspection or test. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.3 Serial number or other identifier of the equipment on which the inspection or test was performed. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.4 Description of the inspection or test performed. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.5 Recommended corrective action(s) for each deficiency identified. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.6 Description of corrective action(s) for each deficiency identified. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.7 Identification of each designated responsible person assigned and authorized to remedy each deficiency identified. OSHA/EPA requirement. Handled in the Management System master recommendation tracking form RT-1. NOT duplicating this information on MI docs.
5.1.1.3.8 Results based on the conditions at commencement of the inspection or test, including instrumentation readings. This is already covered in the ITMPR Corrective Actions, Recommended Actions & Comments section if implemented correctly.
5.1.1.3.9 Expected activation set points (+/-) including a functional description of the control logic. This information is already provided in the respective equipment RESOPs and system level ROSOPs. Since all our ITPMRs are used in conjunction with the SOPs this should be sufficient.
5.1.1.3.10 Results based on the conditions after completion of the inspection or test, including instrumentation readings. OSHA/EPA requirement already handled on ITPMR.
5.1.1.3.11 Expected completion date(s). OSHA/EPA requirement. Handled in the Management System master recommendation tracking form RT-1. This may be handled through a CMMS, but we’re NOT duplicating this information on our MI docs.
5.1.1.3.12 Actual completion date(s). OSHA/EPA requirement. Handled in the Management System master recommendation tracking form RT-1. This may be handled through a CMMS, but we’re NOT duplicating this information on our MI docs.

 

 Challenge #2: Section 5.2, Table 5.2

The IIAR is introducing the same concept here as I did last year with the “Acceptable Task Frequency Window.” I think their window is over-broad and would not be comfortable defending it without further engineering rationale. For example, they are giving a 1 month window on a quarterly task vs. my 14 days, a 2 month window on a semi-annual task vs. my 1 month window. I’m sticking with my more conservative window for now, but – as always – you are welcome to change yours.

  

Challenge #3: Section 5.2

The IIAR is rightly calling out the need to re-evaluate task frequency based on a history of deficiencies. I’ve incorporated some of their wording directly in the MI Implementation Policy: Mechanical Integrity Schedule as follows: Where a history of repeated deficiencies has been recorded, task frequencies / methods should be re-evaluated. This is usually triggered through the Incident Investigation element and managed through the MOC/PSSR element.

The IIAR is also stating “Where a history of fault-free operation has been recorded, the (ITM) task frequencies are permitted to be decreased.” I am not comfortable with incorporating this wording into the written plan as while it is not necessarily wrong it is extremely difficult to defend without providing significant engineering rationale. OSHA has published a lot of guidance saying the opposite of what the IIAR is saying here, and while I believe OSHA is wrong in their guidance, we should probably pick-and-choose your battles better than this.

  

Challenge #4: Section 5.3.6

 5.3.6.1 – This section implements a few new logs/documentation requirements, including the “Procedure for Communicating between shifts” that the CCPS has long recommended. Those using the COM-LOG (as outlined in the Employee Participation Written Plan) were already handling this well. To improve the system though, that section has been moved from the EP plan and placed in the RMP (Management System) Written Plan and renamed “Written Communication Log.”

5.3.6.2 requires documentation on secondary coolants. The ITPMR HX-90 & ITPMR HX-365 already does much of this but a new line adds “If any glycol was added / removed, record the type and amount.” While in this section, removed all the references to Glycol and replaced with Fluid so it can be used with Brine and Glycol systems.

5.3.6.3 requires documentation of the NH3 test records. The required information was added to a new ITPMR: ITPMR-NH3 and it was added to the MI-EL-1.

5.3.6.4 requires documentation of the addition / removal of any oil. Created a new log called OIL-LOG and updated all PU, PV & RC ITPMRS to include a reference to this log during oil addition/draining steps.

5.3.6.5 requires documentation of the lubrication type, quantity needed, and quantity used. Created a new log called the LUBE-LOG and updated all AU, HX, EC, RC & VENT ITPMRS to include a reference to this log during lubrication steps.

5.3.6.6 requires documentation of Relief Valves. I have no intention of creating a log for this as all the information should be in the PSI and whatever work order / ITPMR was used to replace the relief valve. To make this easier, I’ve included new text in the ITPMR-PRV-365 “If the relief valve is to be replaced, the new valve model number and pressure setting must be confirmed and recorded by TWO people before replacement to be considered a “Direct Replacement.” “In-Kind” and other types of replacements must be handled in accordance with the facility MOC policy.” I’ve also included signature boxes in that ITPMR line item.

 

Challenge #5: Section 5.3.7

This section deals with record retention requirements. The advice given here by the IIAR does not seem to reflect the RMP and PSM guidance given by the EPA and OSHA and has therefore been skipped. A careful reading of the informative appendix shows that the drafters of this document understood that MI documentation needs to be kept for the life of the process. In any case, we’re in a digital world so you can avoid the argument entirely if you scan the documents, put them on a cloud-based server, and recycle the paper.

  

Challenge #6: Section 5.4.2

This section replaces the old IIAR B110 5yr Independent Inspection. It includes qualifications & conflict-of-interest requirements. In the informative appendix, they’ve also buried a certification requirement. All these requirements have been added in the Mechanical Integrity Written Plan under the Implementation Policy: Five Year Independent MI Inspection. To make my customer’s lives easier, I’ve also included a Responsible Person certification page in my MI Report Template as well as a signed statement regarding conflict-of-interest signed by the Team Leader for my MI Inspections, PHA’s and Compliance Audits.

  

Challenge #7: Section 5.5.1

This section deals with calibration of the instruments used in tests and inspections. I have included similar requirements in the ROSOP-QA concerning gauges for a long time, but it’s often ignored. We need to re-emphasize this issue! The ROSOP QA Pressure Gauge section was renamed to Testing Instrument and reworded to cover the additional ANSI/IIAR 6-2019 requirements.

PSM Program / Template Changes: The entire template PSM/RMP program was altered to conform with ANSI/IIAR 6-2019. All changes made in the 030219 templates are outlined below:

ALL PSM / RMP Element Written Plan Changes

  • Moved Definitions from individual element Written Plans References and Definitions Section to a stand-alone document. The stand-alone definitions document was placed in the RMP / Management System binder / folder. The total list of definitions was expanded to cover much of the same ground as IIAR 1 – Definitions. Where the definitions I use varied from the IIAR significantly, I added the IIAR definitions with a “Per IIAR, …” at the end of the definition I’m using. Where IIAR definitions are used, they were updated to the most recent version of IIAR 1. Added the new ANSI/IIAR 6-2019 definitions to the stand-alone definitions document.

 

RMP / Management System Element Written Plan Changes

  • Moved Implementation Policy: Written Communication Log (COMLOG) from Employee Participation to this Plan. (Not specifically required by ANSI/IIAR 6-2019 but a good idea I’ve wanted to implement for a while)
  • Moved the content of Implementation Policy: PSM Meeting Notes from Employee Participation to this Plan. Also expanded this section to include some suggested agenda items for PSM Team Meetings. (Not specifically required by ANSI/IIAR 6-2019 but a good idea I’ve wanted to implement for a while)

 

EP PSM / RMP Element Written Plan Changes

  • Renamed Implementation Policy: Communication between Shifts (COMLOG) to Implementation Policy: Written Communication Log (COMLOG) and moved it to the RMP (Management System) Written Plan. (Not specifically required by ANSI/IIAR 6-2019 but a good idea I’ve wanted to implement for a while)
  • Moved content of Implementation Policy: PSM Meeting Notes to Implementation Policy: PSM Team Composition, Meeting Documentation and Agenda in the RMP (Management System) Written Plan. (Not specifically required by ANSI/IIAR 6-2019 but a good idea I’ve wanted to implement for a while)

 

HW PSM / RMP Element Written Plan Changes

  • Updated both versions of the template to include explicit statement on NOT performing Hot Work or using Sulphur Sticks during Charging, or when removing Oil / NH3 from the system. (IIAR 6 5.6.3.4)

 

 PSSR PSM / RMP Element Plan Changes

  • Updated ALL the PSSR forms (Word) to match the new 1yr ITPMRs. Maybe someday I’ll create the PDF forms again but it’s a lot of work and I’d rather we all work with the new ITPMRs to validate / field verify them before I expend that effort.
  • Added new ITR-LP-PSSR for non-ammonia Liquid Pumps

 

 

 

MI PSM / RMP Element Written Plan Changes

 

References and Definitions

  • Added ANSI/IIAR 6-2019 as a standard reference
  • Added IRC MI Guidebook as a standard reference

 

Implementation Policy: Mechanical Integrity Schedule

  • Slight change to first sentence to clarify that this policy is covering the Ammonia Refrigeration System to cover the same ground as IIAR 6 5.1.1
  • Added language concerning modifying the schedule based on a history of recorded deficiencies.
  • Added IIAR 6 5.2.3 language concerning daily tasks not being required during holidays/weekends.

 

Implementation Policy: Mechanical Integrity Task Documentation

  • Modified the Corrective Actions, Recommended Actions & Comments section to improve the explanation of what’s expected in the ITPMR forms to cover the same ground as IIAR 6 5.1.1.3.8

 

Implementation Policy: Access to MIPs and Manufacturer’s Equipment Manuals

  • Modified this section for clarity so that it clearly includes all Process Operators and refrigeration Contractors. Removed specific location wording. (IIAR 6 5.3.2)

 

MI-EL-1 Maintenance Schedule / Checklist Changes

  • Added a line for Generators / Standby power sources (IIAR 6 5.5.4)
  • Added a line for Ammonia Hoses (IIAR 6 11.1.4, 11.1.5)
  • Changed IIAR B110 references to ANSI/IIAR 6-2019
  • Added Filename / Template Revision to the bottom of the Checklist. (Not specifically required by ANSI/IIAR 6-2019 but a good idea I’ve wanted to implement for a while)

 

ITMPR Changes

 

ALL ITPMRS

  • Added color banding. Thanks Scott!
  • Re-organized tasks for more grouping.
  • Set ITPMT tables to repeat Header Row as several ITPMRs are now two pages
  • Standardized (hopefully) the formatting of the numbered / bulleted lists
  • Re-organized the catch-all sections at the end. These are now a little bit longer, but they seem to be easier to read / follow now. Thanks to Scott for the idea.
  • Incorporated some additional items from field feedback. Thanks Jeremiah, Scott & Victor!
  • Added new ITPMR-LP for non-ammonia Liquid Pumps

 

Note: none of the above are specifically required by ANSI/IIAR 6-2019 but I’ve wanted to implement them for a while.

 

ITMPR AHT-365, AHNT-365 (Ammonia Hoses)

  • New ITPMRs based on ANSI/IIAR 6-2019 Table 11.1.4 & 11.1.5 to cover Ammonia Hoses (Transfer and Non-Transfer)

 

ITMPR AC-30, AC-365 (Air Curtains)

  • Added Lube-LOG reference
  • Incorporated IIAR 6 Table 11.1.6 valve items into the annual ITPMRs

 

ITMPR AP-365 (Ammonia Pumps)

  • Added Lube-LOG reference
  • Incorporated IIAR 6 Table 7.1 items into the ITPMRs
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMRs

 

ITMPR AU-90, AU-365 (Air Units)

  • Added Lube-LOG reference
  • Incorporated IIAR 6 Table 9.1 items into the ITPMR
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMR

 

ITMPR DETECT-180 (NH3 Detectors)

  • Incorporated IIAR 6 Table 12.3 items into the ITPMR

 

ITMPR DT-90, DT-365 (Diffusion Tanks)

  • Reformatting / Renumbering for consistency with other ITPMRs.
  • Added leak / freeze protection checks

 

ITMPR EC-30, EC-90, EC-365, EC-SD (Evaporative Condensers)

  • Added Lube-LOG reference (EC-90, EC-365, EC-SD)
  • Renumbered EC-90 to EC-180 (MI-El-1, Checklist)
  • Incorporated IIAR 6 Table 8.1 items into the ITPMRs
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMRs

 

ITMPR HX-90, HX-365 (Heat Exchangers)

  • A new item “If any glycol was added / removed, record the type and amount.”
  • Added Lube-LOG reference
  • Replaced references to Glycol with Fluid so it can be used for Brine systems as well.
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMRs

 

ITMPR MI-5yr (5yr MI)

  • Incorporated new ANSI/IIAR 6-2019 requirements in the ITPMR

 

ITMPR MR-365 (Machine Room)

  • Incorporated ANSI/IIAR 6-2019 Table 12.2 items into the ITPMR

 

ITMPR NH3 (Ammonia)

  • New ITPMR based on IIAR 6 Table 15.1

 

ITMPR PIPE-365

  • Incorporated IIAR 6 Table 11.1 items into the ITPMRs
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMRs

 

ITMPR PRV-365 (Pressure Relief Valves)

  • Included new text in the ITPMR-PRV-365 “If the relief valve is to be replaced, the new valve model number and pressure setting must be confirmed and recorded by TWO people before replacement to be considered a “Direct Replacement.” “In-Kind” and other types of replacements must be handled in accordance with the facility MOC policy.” (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
  • Included verification signature boxes in the valve replacement ITPMR line item. (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMR
  • Incorporated IIAR 6 Table 13.1 items into the ITPMR

 

ITMPR PU-90, PU-365 (Purgers)

  • Combined Hansen and Parker into single ITPMR (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
  • Added Oil Drain line and OIL-LOG reference
  • Incorporated IIAR 6 Table 14.1 items into the ITPMRs
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMRs

 

ITMPR PV-90, PV-365 (Pressure Vessels)

  • Added OIL-LOG reference
  • Added note to “operating within limits” question on PV-365 to remind the user to check pressure and temperature
  • Incorporated IIAR 6 Table 10.1 daily items into the ITPMRs
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMRs

 

RC-30, RC-90, RC-365 (Refrigeration Compressors)

  • ITMPR Removed RC-30 (MI-El-1, Checklist)
  • Added check that setpoints are appropriate for connected vessels (RC-90, RC-365)
  • Added Lube-LOG reference (RC-90, RC-365)
  • Added OIL-LOG reference (RC-90, RC-365)
  • Incorporated IIAR 6 Table 6.1 items into the ITPMRs
  • Incorporated IIAR 6 Table 11.1.6 valve items into the ITPMR

 

ITMPR SS-7, SS-365 (Safety Showers)

  • Incorporated IIAR 6 Table 12.5 items into the ITPMRs

 

ITMPR VENT90, VENT365 (Machine Room Ventilation)

  • Added additional IIAR 2 checks to VENT-365
  • Incorporated IIAR 6 Table 12.1 items into the ITPMRs

 

SOP (RESOP & ROSOP) Template Changes

All

  • While leak-checking was already addressed to some degree, there was some room for improvement. A leak check reminder has been placed in the LEO Return to Service A leak check task has been placed in ALL equipment SOP steps that open Isolation Valves in the Normal Startup procedural section (IIAR 6 5.5.3)
  • Where it wasn’t already done, all Normal Startup steps re-arranged to ensure that we are opening the unit to the system starting with he lowest threat and working towards the greatest threat: suction -> DC -> hgd -> liquid (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
  • For ALL Equipment RESOPS:
    • Slightly reworded Emergency Shutdown section to make it simpler. (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
    • Removed any specific MI steps from the Maintenance sections. We’re simply kicking it to the MI-El1, equipment-specific ITPMR’s and IOM’s. (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)

 

ROSOP LEO – Line & Equipment Opening

  • Added leak check reminder in Return to Service section.

 

ROSOP SWT – System Walkthrough

  • Incorporated all ANSI/IIAR 6-2019 tables daily / weekly items into the ROSOP
  • Changed “Engine Room” to “Machine Room” everywhere I could find it! (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
  • Harmonized text between the RESOP “Monitor Normal Operations” sections and this document. (Not specifically required by IIAR 6 but a good idea I’ve wanted to implement for a while)
  • Added Autopurgers to Machine Room section

 

ROSOP QA – Quality Assurance

  • Added a section on Ice Accumulation (IIAR 6 5.6.8)
  • Updated Vessel & Pipe sections to include new guidance on corrosion. (IIAR 6 10.1.1-2)
  • Updated Pipe section to include new guidance on allowable thickness, Table A.11.1.1.3.1 Piping Sizes, Schedules, and Thicknesses (IIAR 6 A.11.1.1.3.1)
  • Updated Vessel section to include new guidance on nameplates. (IIAR 6 10.1.4)
  • Renamed Pressure Gauge section to Testing Instrument and provided additional ANSI/IIAR 6-2019 requirements. (IIAR 6 5.5)

 

RESOP AP – Autopurger

  • Incorporated Table 14.1 (autopurgers) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.

 

RESOP AU – Air Unit

  • Incorporated Table 9.1 (evaporators) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.

 

RESOP C – Compressors

  • Incorporated Table 6.1 (compressors) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.

 

RESOP EC – Condensers

  • Incorporated Table 8.1 (condensers) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.

 

RESOP HPRTSR – Non-recirculating Vessels

  • Incorporated Table 10.1 (vessels) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.

  

RESOP HTR – Recirculating Vessels

  • Incorporated Table 7.1 (pumps) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.
  • Incorporated Table 10.1 (vessels) daily items into the Monitor Normal Operations Section.

  

RESOP HX – Heat Exchangers

  • Incorporated Table 9.1 (evaporators) daily items into the Monitor Normal Operations Section and harmonized that section with the ROSOP SWT Walkthrough procedure.

 

 

Responding to an OSHA NEP Inspection Document Request

Back in 2017 I posted on how to answer an OSHA document request from the published NEP.

OSHA’s published CPL-03-00-021 – “PSM Covered Chemical Facilities National Emphasis Program” includes an example document request list that often correlates fairly well to the one that OSHA inspectors provide during an NEP inspection.

Recently, a friend sent me the Document Request they received at the onset of the inspection which was quite a bit different from that PSM ChemNEP. Here’s what I noticed reviewing this new document:

  • It’s quite a bit longer.
  • The information – again – isn’t NH3 Refrigeration Specific. That means you have to interpret some of it.
  • In my opinion, It’s designed to be a huge fishing expedition.

I took that request and modified it to show how I would answer the 110 questions if you were using my PSM programs. You can download the 13 page, 4,500 word Microsoft Word monstrosity through the following link: 0419 OSHA Document Request.

Just a few general warnings about questions and document requests:

  • When in doubt, ask for clarification. Always get clarifications in WRITING.
  • When you are unsure of the appropriate documentation to provide, or what documentation addresses the issue, ask to get back to them and seek quality advice.
  • Always get additional documentation requests and follow-up questions in WRITING.

Remember, you can watch a 30 minute presentation on YouTube regarding preparing for (and surviving) an OSHA / EPA inspection here.

Composite Fan Blades – A Replacement in Kind?

Imagine we’ve decided to replace the existing fans of an air unit (probably a blast cell) with composite blades. Should you consider that a Replacement in Kind?

Before we go into the change, you might be asking why people would change from a metal fan to a composite. The answer is usually three-fold:

  • Composites allow for some really elaborate / efficient shapes that are difficult to pull off with traditional metal blades. This means that the fan blades can be designed for low noise or to maximize throughput / throw. It’s not uncommon to see a composite blade manufacturer claim a 5% energy savings by using these types of fans.
  • Corrosion Resistance. The commonly used FRP (Fiber reinforced polymer) blades are more resistant to common cleaning chemicals and water than traditional metal fans.
  • Composite fans usually provide a far better weight/strength ratio than even cast aluminum. This means higher efficiency, lower motor wear, etc.

Should you consider the replacement of traditional metal fans (in an air unit for example) as a Replacement in Kind? My thinking on this is the same as the answer to every other “Is it a Replacement in Kind” question: It’s a change that falls under the MOC procedure(s) until you prove that it isn’t.

To meet the lowest possible compliance threshold of OSHA and the EPA we have to know if it “satisfies the design specification.” In this case, that pretty much comes down to asking if it has the same (or better) performance characteristics as the fan it’s replacing.

Assuming you do those checks, and you find the new fan can operate at the same temperatures, static pressure, speed, etc. as the old fan, OSHA and the EPA would allow us to qualify this as a Replacement in Kind. As always, I would suggest you document that work so you can prove you’ve correctly qualified the change as a Replacement in Kind. That’s the minimal compliance answer. The process safety answer is different and it’s the answer you should care about!

For the process safety answer we also ask a few more questions. For example:

  • Does the fan have the same MI requirements?
  • Does the fan have the same failure modes?
  • Are our PHA answers concerning fans (evaporators, condensers, etc.) still the same based on these new fans?

I would like to focus on the PHA question because the others are part of our PHA answer. If you are using the IIAR’s What-If checklist (or something like it) you have a question that looks like this:

EV1.22  What If…a fan fails catastrophically? (air unit cooler only)

It’s likely you answered that for metal fans by saying there were appropriate safeguards to control this hazard such as your MI program, daily walk-through’s, 5yr independent inspections, etc. It’s also likely that if you had those safeguards in place you made “no recommendation” on that question.

Now, let me ask: What if the new fans have different failure modes / MI requirements? Wouldn’t that change your analysis?

Recently I’ve been getting reports of fan failures in the field. While not unheard of with traditional metal fans, these reports lately seem to all be about composite fan blades.

What we seem to be seeing in these composite fan failures is that they appear to be caused by:

  • Turbulent uneven air flow through the coil (usually caused by debris on the coil but could also be caused by partially blocking the airflow out of a coil)
  • The turbulent air flow causes the fan to oscillate, sometimes at a resonant frequency
  • Over time this resonant frequency causes small stress cracks to start on the fan blade at the hub
  • If the condition lasts long enough, the crack propagates, and the fan catastrophically fails

Now, that’s not a failure mode / sequence of events we are used to seeing on traditional metal fan blades. Does that mean we shouldn’t use composite blades? No, of course not – it means Identifying new hazards like this requires us to institute new / altered controls. Some good examples of appropriate changes:

  • LOWER our acceptable threshold for debris on air unit intakes. This could mean more walk-through’s or just more debris removal. We’re not talking about dust buildup here, we’re talking about the removal of large debris: cardboard chunks, labels, etc. The things that are likely to cause turbulent and uneven flow through the unit.
  • LOWER our acceptable threshold for product blocking airflow out of a coil.
  • Specifically look for signs of cracks during annual / 5yr MI inspections.

Making changes to our program like this show us that the change from a traditional fan blades to composite fan blades should not be treated as a Replacement in Kind. It is, however, a fairly simple Management of Change. I want to re-emphasize here, had we chosen to view this change as a Replacement in Kind, we would have missed these opportunities to identify and control these new hazards introduced by the change.

IIAR 5 updates out for Public Review

The IIAR has announced the Second (2nd) Public Review of BSR/IIAR 5-201x, Startup of Closed-Circuit Ammonia Refrigeration Systems. This is another “partial” review in that it only shows the changed text in context, not the whole standard. I can already see that the PSM-related section in 5.4.1 is tying itself in knots trying to avoid using the term “review the PHA” like the new IIAR Compliance Guidelines draft will. Your review of these documents – and your subsequent comments – help guide our industry.


 

March 22nd, 2019
To: IIAR Members
Re: Second (2nd) Public Review of BSR/IIAR 5-201x, Startup of Closed-Circuit Ammonia Refrigeration Systems

A second (2nd) public review of draft standard BSR/IIAR 5-201x, Startup 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 5-201x, defines the minimum requirements for startup of closed-circuit ammonia refrigeration systems. It presupposes that the persons who use the document have a working knowledge of the functionality of an ammonia refrigeration system(s) and basic ammonia refrigeration practices and principles. This standard is intended for those who startup closed-circuit ammonia refrigeration systems. This standard shall apply only to stationary closed-circuit refrigeration systems utilizing ammonia as the refrigerant. It supplements existing general refrigeration standards issued by IIAR and other organizations such as ASHRAE, ASME, and ANSI. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes).

IIAR has designated the draft standard as BSR/IIAR 5-201x. 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 5-201x. 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 5-201x, and is responsible for the technical content of the standard.

This site includes links to the following attachments:

 

The 30-day public review period will be from March 22nd, 2019 through April 21st, 2019. Comments are due no later than 5:00 pm Eastern Standard Time (EST) on April 21st, 2019.

Thank you for your interest in the public review of BSR/IIAR 5-201x, Startup of Closed-Circuit Ammonia Refrigeration Systems.

Contractors and their work on our NH3 Refrigeration Systems

It’s an all too common occurrence to receive a phone call that starts something like this:

I had some work performed by a contractor over the weekend. Do I need to fill out any paperwork for that?

Short answer, YES.

Long Answer: You should have done that AT THE TIME so now you might want to also consider an Incident Investigation to figure out how you managed to avoid your PSM program requirements on Hot Work, Line-Opening, SOPs, Management of Change, Pre-Startup Safety Review, etc…

These situations are humbling for all involved. It’s helpful to remember that Compliance is a goal we are always striving towards. Still, if we’ve been providing this information the same way for YEARS and it’s still not getting through, part of you begins to wonder if there isn’t a better way (cue the infomercials) to establish BASELINE awareness of these requirements. PSM programs have included guidance on ALL these requirements for decades, but it doesn’t seem to be translating into effective action.

Perhaps there is another way to jump-start that awareness? In an attempt to do just that, I created a simple little flowchart to give to Operators AND Contractor Service Technicians / Construction personnel.

To integrate this into the overall PSM/RMP program, this was placed in the Program Management System Written Plan in the first binder of the PSM program that (in my systems) is entitled “01 – EPA RMP.” The new section is directly after the “Implementation Policy: Management of Program Activities” section.

I also referenced this guidance where appropriate throughout the program. In the same Program Management System Written Plan’s “Implementation Policy: Management of Program Activities” section, the text was altered to point to this new guidance.

  • Activities Triggered by a Change: Certain PSM/RMP program activities are triggered when a change is made to the ammonia refrigeration system. See the “Implementation Policy: Management of Contractor / Operator Activities” for informative guidance and then consult the MOC/PSSR Written Plan to manage and track these activities.
  • Activities Triggered by Maintenance to the Systems: Maintenance to the system can trigger other PSM/RMP program policies / procedures. Examples include Lockout/Tagout, Line & Equipment Opening, and Hot Work permit procedures.  See the “Implementation Policy: Management of Contractor / Operator Activities” for informative guidance and then consult the Mechanical Integrity Written Plan to manage and track these activities.

It’s referenced in the Mechanical Integrity Written Plan in the “Implementation Policy: Quality Assurance” section which now ends with:

See the “Implementation Policy: Management of Contractor / Operator Activities” for additional informative guidance concerning operator and contractor work conducted on the system.

It’s also referenced in the Contractor Written Plan in the “Implementation Policy: Our Responsibilities concerning Affecting Contractors” and “Implementation Policy: Affecting Contractors responsibilities” sections which now end with:

See the “Implementation Policy: Management of Contractor / Operator Activities” for additional informative guidance concerning contractor work conducted on the system.

Fourth (4th) Public Review of Standard BSR/IIAR 2-2014, Addendum A, Standard for Safe design of Closed-Circuit Ammonia Refrigeration Systems.

February 8, 2019
To: IIAR Members
Re: Fourth (4th) Public Review of Standard BSR/IIAR 2-2014, Addendum A, Standard for Safe design of Closed-Circuit Ammonia Refrigeration Systems.

A fourth (4th) public review of draft standard BSR/IIAR 2-2014 Addendum A, Standard for Safe 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 2-2014, Addendum A 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 supplements existing general refrigeration standards issued by IIAR and other organizations such as ASHRAE, ASME, and ANSI. It is not intended to supplant existing safety codes (e.g., model mechanical or fire codes).

IIAR has designated the revised standard as BSR/IIAR 2-2014, Addendum A. 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 fourth (4th) public review of BSR/IIAR 2-2014, Addendum A. 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 2-2014, Addendum A, and is responsible for the technical content of the standard.

This site includes links to the following attachments:

The 30-day public review period will be from February 8, 2019 to March 10, 2019. Comments are due no later than March 10, 2019.

Thank you for your interest in the public review of BSR/IIAR 2-2014, Addendum A, Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems.

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