2017 RETA Breeze Sept-Oct

SAFETY

WHAT DO I NEED TO DO? Under 10,000 Pounds of Ammonia:

By Kent Harmon, Industrial Consultants RETA Education Chairman

Compiling and updating the following information is essential to GDC compliance: • Process Safety Information (PSI), including current P&ID’s (NOTE: A crucial guideline to be considered is in IIAR Bulletin #110 - Section 4: Records); • Process Hazard Analysis (PHA) with discussion of potential release scenarios and their impacts; • operating procedures; • training; • pre-start up procedures; • mechanical integrity; • preventive maintenance; • hot work permit; • incident investigation; and • emergency actions, planning, and response. Everyone who deals with PSM knows they must comply with the fourteen elements. For those with less than 10,000 pounds, I like to say there are the nine elements they must comply with. Even though compliance can seem confusing, remember “How do you eat a whale? One bite at a time. Little bites will get you there.” Be compliant, be safe.

Bigger facilities that have over 10,000 pounds know that they have to comply with the OSHA-PSM standard. Facilities with less than 10,000 pounds sometimes do not know or understand what is required for them. When a facility has less than 10,000 pounds of ammonia in the facility system, both OSHA and EPA use their respective General Duty Clause(GDC) and or Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) to inspect and generate citations. These clauses describe the responsibilities owners and operators have for being diligent in preventing chemical releases. This includes both an employer’s recognition of hazards — and —MOST importantly the industry’s recognition of hazards! The most prominent ammonia refrigeration consensus standards are issued by IIAR (IIAR Suite of Standards, most especially IIAR 2) and ASHRAE (Standard 15). Complying with a GDC basically involves the following: • identification and assessment of process hazards; • maintaining a safe process system; • minimizing consequences of any ammonia release; and • MOST IMPORTANT — adhering to industry codes and standards. (NOTE: This is commonly referred to as RAGAGEP.)

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