Category: Uncategorized (Page 1 of 3)

EPA Proposes to change the RMP rules (again)

Looks like the Biden administration is going to continue the recent streak of attempting to change the EPA RMP rules that was started in the Obama administration.

Risk Management Program Safer Communities by Chemical Accident Prevention Proposed Rule

On August 18, 2022, EPA Administrator Michael S. Regan signed the Safer Communities by Chemical Accident Prevention (SCCAP) rule, which proposes revisions to the Risk Management Program (RMP) to further protect vulnerable communities from chemical accidents, especially those living near facilities with high accident rates. The proposed rule would strengthen the existing program and includes new safeguards that have not been addressed in prior RMP rules. Some of the proposed requirements include identifying safer technologies and chemical alternatives, more thorough incident investigations, and third-party auditing, all of which should benefit nearby communities. When finalized, the rule is expected to make communities safer by reducing the frequency of chemical releases and their adverse effects.

The public may comment on the SCCAP proposed rule at www.regulations.govEXIT EPA WEBSITE (Docket ID No.: EPA-HQ-OLEM-2022-0174) until 60 days after publication in the Federal Register.

View the Prepublication Version of the Federal Register Notice for the RMP Safer Communities by Chemical Accident Prevention Proposed Rule (pdf) (2.2 MB)

Note: This previous post covers the history over the past 3 presidential administrations.

Can long Lead Times impact Process Safety?


“Time Waits for No one…”

The Issue at hand

When I first started in NH3 refrigeration, you could pick up the phone, talk to your parts-guy, and get a replacement valve quickly: often the same day, but usually within a business day or two. While you were waiting for the part, you either operated the equipment manually (requiring a temporary SOP / MOC) or shut the equipment down during the wait. We call the time between when you order something and when it arrives, lead-time.

Because lead-times *were* short, parts inventory at most facilities were kept fairly low – usually limited to what would stop production. If you could get what you needed in a day or two, why keep it on the shelf, unless you were losing 20k+ an hour in downtime?

The situation has changed around us, and I’m not sure we’ve all thought through the implications of the current supply-chain issues. Lead-times have grown substantially in 2021 and, while relief is promised in the second half of 2022, these long wait times for equipment and components have the potential to adversely affect our Process Safety.

 

Current Lead Time estimates

Equipment / Component Lead-Times in Weeks*
Valves, Shutoff and Control 14-24
Valves, Relief 12-20
Vessels 14-24
Condensers 14-16
Compressors 16
Air Unit / Evaporators 36
Heat Exchangers 14

*Typical for NH3 components. Varies by brand. Some halocarbons lead-times are even longer.

 

How can this affect Process Safety?

When you don’t have a critical spare part, and won’t have one for several months, production demands are likely to force you to operate your equipment in “temporary” modes. Here are a few thoughts:

  • Temporary is a vague term, but we don’t normally think of temporary as “weeks” or “months”. Put this in more personal terms: if your city tells you they are working on a water main and you will be without water for 8hrs, your response is quite different than if you are going to be without water for 3 months. Not having running water for a few hours means you pour some in a pitcher and delay some dish washing / bathing. Not having water for months requires an entirely different approach.
  • It is very likely that the PSM element where you “identify hazards and control them” (the PHA) was based on customary lead-times, not the ones we are now facing!
  • If operating in a temporary mode has negative safety implications, it is far easier to make the argument that we should forgo production for a few hours, or that we can handle manual operations for a few hours, than it is to justify these “temporary” arrangements for several weeks or months. As an example, if an automatic makeup feed valve to a vessel fails, it’s not terribly difficult to manually manage that for a few hour manually while your parts provider gets you the new valve. It’s far more difficult to manage that issue around the clock for several weeks or months!

 

What should I do?

“The first responsibility of a leader is to define reality…” –Max DePree

Well, the first step is to start a discussion with your skilled technicians and make sure they understand the environment we’re all working in. Here are some points for discussion, and further actions to take:

  • Get a good understanding of the lead-times for the replacement components in your system.
  • With that understanding, talk with your skilled technicians about what is critical for operations.
  • Discuss what you’ve learned so far with operations / production management so you can understand what they “need” and they have a better understanding of these issues.
  • Review your PHA (with all the above in mind) to see what (if any) changes you might need to make to your spare parts/equipment inventory. You might want to bias towards a higher on-site inventory, and (especially if you are using a CMMS or other parts control software) increase your “minimum” inventory to 1 or 2, rather than zero.
  • Order what you need.
  • Consider pre-writing some “temporary” SOPs for operations when failures of critical components occur.

RC&E can assist you with your parts and spares. Click Here for our Line Card. Call Dennis Vaught 817-210-1957 or email him at [email protected]

Safety Bulletin on P-Series Valves

R/S has just released a safety notification regarding the solenoid operator and LED light for the PVS and P-series valves (PA4 regulators and PS4 solenoids).

 

Subject: P-Series Coil Installation and Removal Notification

To properly install and remove solenoid coils on Parker P-Series products:

  • Place the solenoid coil over the solenoid operator.
  • Install the wave spring (included with the coil) over the Solenoid Operator on top of the coil.
  • Inspect the Solenoid Operator threads for damage. If the threads are damaged, the Solenoid Operator Assembly must be replaced.
  • Thread the coil retaining nut (included with the coil) or optional LED knob onto the Solenoid Operator until it contacts the wave spring. Take caution to avoid cross threading.
  • Rotate the nut or knob an additional ¼ to ½ turn, compressing the wave spring.
  • To remove the coil, unthread the coil retaining nut or the LED knob. Torque must not exceed 5 ft-lb.

If cross threading occurred or the threads were damaged, excess torque may be required for removal. This higher torque could unthread the solenoid operator from the valve leading to a refrigerant leak. If the unthreading torque exceeds 5 ft-lbs, the refrigerant in the valve must be evacuated before proceeding.

Do not open to atmosphere the valve, strainer or control until refrigerant had been evacuated. All personnel working on valves must be qualified to work on refrigeration systems. Any person intending to service a valve should read the appropriate product and safety bulletin before performing any work on R/S products.

Please pass this information on to your NH3 refrigeration operators!

 

You can download the safety bulletin at this link.

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.

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.

How Many Operators do we Need?

Disclaimer: This post is a collaboration between an industry friend and colleague, Victor Dearman and I. The views expressed here do not necessarily represent the opinions of any entity whatsoever which we have been, are now, or will be affiliated.

It’s a question we hear often – sometimes as part of a PHA or Compliance Audit, but more often with someone just struggling to justify their staffing requests. Unfortunately, there really isn’t a simple, definitive answer to the question. No controlling RAGAGEP exists and state / local laws on the topic are relatively rare. This sort of problem isn’t rare in PSM because it is a performance-based standard. Our performance basis is that we are staffed sufficiently to ensure the safety of the people within the building and the surrounding community.

We need to answer the “How many Operators do we need?” question in a way that we can support it, or as we like to say, “Build a defensible case for the answer we arrive at. The answer itself will depend on many, many factors. So, let’s go on a journey and see how we can arrive at an answer we can feel confident in.

 

The road to an answer

The biggest factor for many is the design (age!?) of the system controls. A modern system with advanced controls requires less oversight on a day-to-day basis. If your system still relies on manual controls and people writing down pressures every hour, then that’s going to have a significant impact on your staffing needs. But once we get past that obvious issue, things get a bit more complicated.

Let’s be honest here, if things are running well; you have a good history with compliance audits, inspections, incident investigations, etc. and a low MI backlog, you’re probably not asking this question. If you are asking this question, it is probably due to an event related to a PSM/RMP element.

Let’s look at the kinds of element events that typically lead to this question.

  • Employee Participation
  • Mechanical Integrity
  • Incident Investigations
  • Management of Change / Pre-Startup Safety Review
  • Process Hazard Analysis
  • Emergency Action and Response Plans

 

Employee Participation: Look, everyone feels over-burdened at work, especially in the modern “Do MORE with LESS” era. But, if you pay attention to it, and look at these other elements, this employee feedback can provide valuable insights into the adequacy of your staffing.

 

Mechanical Integrity: What we’re looking for here is to understand if you have the skill sets and staffing to adequately maintain your refrigeration system. Whether you do everything in-house, or have a small in-house small crew performing basic rounds and contract out all the rest of the maintenance, inspections, and tests, is it adequate?

Here’s some MI related questions you might ask to help you determine if your staffing is adequate:

    • Are we properly implementing our Line & Equipment Opening (sometimes known as line break) procedures?
    • Are we caught up on ITPMR’s (Inspection, Test and Preventative Maintenance Reports) or work orders?
    • Is the documentation of ITPMR’s, Work orders, Oil Logs adequate?
    • Are we performing our scheduled walk-through’s and documenting them properly?
    • Are we addressing MI recommendations in a timely manner?
    • Are there indications that maintenance of the facility and system are being conducted properly and required repairs aren’t being delayed?
    • Are there no indications in the written MI records, or in your observations, that the system is running outside the written operating limits?

 

Incident Investigations: A review of incident investigation history can tell us a lot if the facility has a good process safety culture. But if they don’t have the right culture, and /or they don’t have any documented incidents, you’re going to have to do a little detective work and interview plant employees to find out if incidents are occurring that aren’t being recorded. Remember to spread your net wide here because incidents can happen at any time, not just on day-shift: Backshifts, weekends, holidays, etc. there’s no time immune to a possible incident.

You may also find indications of incidents occurring in walk-through logs, communications logs, ITPMRs, work orders, etc.

Here’s some II related questions you might ask to help you determine if your staffing is adequate:

    • Are incidents being reported, conducted, and documented? If not, is this a culture issue or a staffing issue?
    • Are incidents and incident report findings & recommendations being addressed, communicated, and followed to their conclusion?
    • Are there incidents that could have avoided with proper staffing?
    • Are there incidents that would have their severity reduced with proper staffing?
    • Are there incident investigations with recommendations that could be addressed with proper staffing?

 

Management of Change / Pre-Startup Safety Review: Properly implementing the MOC and PSSR elements takes a lot of time! We often find that these two elements are amongst the first to “fall behind” in suboptimal staffing situations. Here’s some MOC/PSSR related questions you might ask to help you determine if your staffing is adequate:

    • Have MOCs / PSSRs been conducted when they were supposed to be?
    • Were the MOCs / PSSRs conducted adequately to properly manage the hazards related to the change and the new systems?
    • Is the documentation of MOCs / PSSRs complete?
    • Are there any open items or recommendations from MOCs, PSSRs, or project punch lists?

 

Process Hazard Analysis: The PHA and open PHA recommendations can also help us understand if our staffing levels are appropriate. There may also be indications in the PHA itself. There’s a portion of the PHA that deals with staffing directly, but we’ll deal with that in the Building a defensible case on staffing section of this article.

Here’s some PHA related questions you might ask to help you determine if your staffing is adequate:

    • Are the PHA recommendations being addressed, communicated, and followed to their conclusion?
    • Is the facility provided with modern controls, alarm systems and equipment? (Newer, modern facilities often have significantly lower staffing needs than older ones)
    • Has the PHA been updated / validated as required by MOC activities and the 5yr schedule?

 

Emergency Action and Response Plans: Whether we’re looking at the plan(s) themselves, or analyzing an after-action report, a there can be a lot to learn here concerning proper staffing levels. Obviously, the required staffing levels for Emergency Response facilities is going to be higher, but that doesn’t mean there is no staffing requirement for Emergency Action plans.

Here’s some EAP/ERP related questions you might ask to help you determine if your staffing is adequate:

    • In the event of an incidental release of ammonia, do you have adequate staffing to investigate and respond?
    • In the event of an emergency response, even if you are not a “responding” facility, do you have adequate staffing to ensure that the equipment is properly shut down?
    • If you are a “responding” facility, do you have enough adequately trained personnel to staff your response team including an Incident Commander, safety officer, decontamination personnel, two entry teams, etc.
    • If you bring key staff back on-site to deal with emergencies, are they close enough to respond in a timely manner, or do you need to increase the size of your trained response team?

 

Building a defensible case on staffing

Ok, we’ve answered our questions and gathered a good impression of where we stand – and where we should stand. Maybe we need to adjust our staffing levels and/or increase the amount of services we ask contractors to complete for us. Where should we document this? In our opinion, the place in the system where the facility already had the opportunity to address this issue, was in the PHA. So, let’s go back to the PHA, end see if our results match the PHA team’s.

You are going to be looking for the following two questions (or their equivalents) from the standard Human Factors section of the IIAR What-If /Checklist worksheets:

HF14.37 – What if an employee is stressed due to shift work and overtime schedules?

HF14.38 – What if there are not sufficient employees to properly operate the system and respond to system upsets?

During the PHA, the facility should have answered those in a way that says they have adequate staffing or recommended that staffing be increased. Let’s say you decided that you had adequate staffing based on your answers to the questions above. If that’s the case, we’d expect to see something like the following:

 

If, however, we found some areas for improvement, we might expect something like this:

 

Closing Thoughts: We hope you didn’t start reading this hoping for an easy answer, but we’re fairly certain – now that you understand the full scope of the question being asked – that the answer doesn’t need to be easy, it needs to be correct and defensible.

You can build a much better understanding of your staffing needs by looking at the existing elements in your Process Safety program. Any decent Compliance Audit would cover this same ground, if staffing is an area of concern for you, make sure to bring it up.

P.S.  from Victor: Some facilities might try and get more value from a security guard on off shifts or holiday coverage to make roving patrols and report abnormal conditions and alarms? Sure, but that also means that guard has to be trained to identify what the alarms mean, how to identify an abnormal condition, and that they know what to do to either immediately correct the deviation or immediately contact someone that can (on call techs or service providers). By the time you have invested this much into a guard, you could have paid for a well-qualified operator.

My advice to any organization when making these decisions is to evaluate the above and take into consideration the attracting well rounded operators with the skill sets and experience often sought is more often through word of mouth about how the organization projects their Process Safety culture.

How to hire operators? Well, that sounds like a good subject for a future article!

What is the best way to train my ammonia refrigeration operators?

Nearly 3 years ago we posted an answer to the question “What training does my refrigeration operator need?

In our experience, to get a good understanding of the Overview of ammonia refrigeration – the fundamentals of how it works – facility provided one-on-one hands-on training is the most effective training approach. This is the approach used for the vast majority of the skilled trades and it is proven effective. Unfortunately, if you don’t already have in-house expertise, there’s nobody to provide the training! A facility lacking on-site talent to act as trainers is when 3rd party providers can provide some value.

We’ve been getting a lot of questions lately centered around getting the best “bang for your buck” when using outside training providers. This post is solely about operator training. That is, the training we need to provide for our refrigeration operators that can be done by outside training providers – Process Safety training will be addressed briefly at the end.

If you don’t already understand that the training these providers offer is usually only going to address a small portion of the overall PSM training requirements, please read “What training does my refrigeration operator need?” before proceeding. I’ll reinforce a key point from that post though: The standard classes offered by most ammonia “schools,” even if they are done properly, only address a portion of the training burden – a small piece of the Overview of the Process requirement. You cannot send your personnel off to some 4-day class and get a qualified operator in return. (Buying a laminating machine doesn’t give you any authority to certify operators, but that’s another post. If you want credentials that matter, go to RETA)

We’re going to answer this question in three parts:

  • What kinds of programs are there?
  • What are the benefits and drawbacks of each training approach?
  • What training approach do we recommend?

 

What kinds of programs are there?

Broadly speaking, the available options break down into three groups:

  1. Self-directed
  2. Instructor based ON-site
  3. Instructor based OFF-site

Self-directed: You give your employee access to refrigeration books (such as the excellent RETA series) and they teach themselves the topic. You might also supplement this with online training which provides feedback and automated testing such as the RETA online training.

Instructor based On-site: Various training providers offer classes taught by an instructor at your facility.  These classes usually run 8-10 hours a day for 3-5 days.  With your approval, the class can use your refrigeration system for any illustration or “hands-on” purposes. If you have enough students, you can make these classes private – meaning only students from your company attend. This allows you to customize the content to reflect your policies. It also allows you to be a little more open about your practices and shortcomings in class discussions.

Instructor based Off-site: Various training providers offer classes taught by an instructor at the training companies “school.” These classes usually run 8-10 hours a day for 3-5 days.  Some of these training providers have built small refrigeration systems (“labs”) that they use to illustrate concepts during “hands-on” sessions. Like the on-site classes, if you have enough students, you can make these classes private.

 

What are the benefits and drawbacks of each training approach?

Program Type Pro Con
Self-directed
  • Lowest cost
  • Flexible scheduling (can be done during low demand times and in off hours)
  • Self-paced
  • Students can pick-and-choose relevant topics and avoid things that don’t apply to your system.
  • Online versions offer good documentation and testing feedback.
  • Bad fit for people that aren’t self-starters
  • Requires above-average reading comprehension skills
  • Questions need to be directed to on-site resources so if you don’t have them, you must reach out to contractors or industry colleagues.
Instructor based ON-site
  • Lower cost compared to Off-site because you avoid lodging, travel, travel time, and most meal expenses.
  • You can set up the class time block for a time convenient to your operations. Many facilities choose to schedule these classes during an off-season.
  • Students are available on-site in case of actual facility emergencies.
  • Instructor-based training can be more responsive and open to questions.
  • “Hands on” and procedural training can be done with your actual equipment and procedures & policies.

 

  • Higher cost compared to self-directed
  • While you can schedule the instruction for any convenient time block, once you have the time locked in, students need to be able to stay in the class during the entire time block.
  • Usually the minimum class size is 8-10 people, so you have to pull a lot of talent into this class or open it up to others. Once you open it up, you also lose the ability to customize the class.
  • There is a tendency to pull students out of the class during the instruction for maintenance “emergencies” more than is actually necessary.
  • Class pace is dictated by the class schedule and tends to move at the pace of the slowest learner in the group. 
  • Many facility’s lack adequate training classrooms. At a minimum, you need a quiet, comfortable space with a projector and screen.
  • Content is usually set, and your students may learn about a lot of equipment and technologies that aren’t applicable to your system. If you are performing a sole-company class, the content can be customized to your needs and equipment, but this may cost extra.
Instructor based OFF-site
  • Students are off-site and can’t be pulled for emergencies.
  • Instructor-based training can be more responsive and open to questions.
  • Most training providers provide clean, comfortable training classrooms.
  • Highest cost when you factor in travel costs, travel time, lodging, meals, etc.
  • You must arrange to meet the schedule of the training provider.
  • Your students are off-site and not available for any facility emergencies.
  • Even though the students are off-site, they will probably be pulled away for endless phone calls and teleconference meetings.
  • Class pace is dictated by the class schedule and tends to move at the pace of the slowest learner in the group. 
  • “Hands on” and procedural training are not done with your equipment and procedures & policies.
  • Content is usually set, and your students may learn about a lot of equipment and technologies that aren’t applicable to your system. If you are performing a sole-company class, the content can be customized to your needs and equipment, but this may cost extra.

 

What training approach do we recommend?

Unless your operators are natural autodidacts (PSM people often prefer learning out of books, for example) self-directed training is not a good fit for most operators. For most organizations, your best bet is instructor-based learning.

As with any training, the more relevant you can make it to your day-to-day operations, the more effective it will be. When you don’t have the on-site expertise to provide training, we think Instructor based ON-site training is the best choice for most organizations. It tends to be more focused on your equipment, procedures & policies and it is more cost effective than off-site training.

One last note: Be extremely mindful of your selection of a 3rd party provider for ANY training, because the instructor’s attitude and knowledge may well affect your safety culture.

PSM-ONLY Note: if you are looking for PSM training – training on how to be a PSM coordinator, or simply to better understand Process Safety systems – then we’d recommend the same as for operator training. But, most organizations don’t have someone sufficiently skilled to provide one-on-one training, so we’re left to seek a 3rd party. Unfortunately, most facilities don’t have enough people for a full class either, so you either need to combine with other facilities in your company (which allows you to have customized training on your policies & procedures) or combine with other organizations to get enough people for an in-house class. Because this is difficult to do, the Instructor based OFF-site option becomes the only one available. While we don’t provide Operator Training, we do offer PSM training.

 

Bonus editorial content: How important is “hands-on” training?

For the purposes of these classes, it is my opinion that the “hands-on” portion of these classes, as it is usually provided, is of little to no value. WHAT!? Allow me to explain:

  • Learning Styles: “But my operators all claim to prefer a ‘hands-on’ learning style!” or “Our operating staff are tactile learners” you say. The idea of learning styles is most likely a “neuromythology” – a popular idea that endures despite having little evidence to support it. In any case, these classes usually don’t really let them “operate” the system in any meaningful way so the “benefit” of “tactile” learning due to “hand-on” training is minimal…
  • “Hands-On”: I used to be an instructor in an organization that provided a lot of classes in the on-site and off-site instructor-based model. The organization provided a lab with “live” ammonia refrigeration systems. Typically, the students spent about a third of their time in this lab, in a group setting. In my opinion, this lab time had very little value for most students. Again, these classes usually don’t really let them “operate” the system in any meaningful way so they are just turning a few valves and conducting exercises in locating valves on PIDs. Certainly, you can manage that level of “hands-on” training at your facility! (I’m sure you can understand why: the liability in letting students operate equipment is HUGE.)

Furthermore, this lab equipment is not the same equipment in your facility, and I can assure you (unless you are woefully non-compliant with General Duty, General Industry standards and PSM/RMP) that their procedures & policies are not YOUR facilities procedures & policies. Most of the benefit that can be gained from “hands-on” training should be done at YOUR facility with YOUR equipment using YOUR procedures and policies. This is how and where the vast majority of your training should actually happen.

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