2018 RETA Breeze May- June

SAFETY

Regardless of the amount of ammonia you have on site (in a single process), you will at some point, whether for compliance with a specific regulation or in accordance with the EPA General Duty Clause, conduct a Process Hazard Analysis.

ose that have in excess of 10,000 pounds of ammonia in a single process, are required to complete a Process Hazard Analysis in accordance with the following regulations: • EPA Risk Management Program (40 CFR Part 68.67) • OSHA Process Safety Management (29 CFR 1910.119 (e)) For those with less than 10,000 pounds, the General Duty Clause mandates that you determine the potential hazards at your facility and what better way than to complete a Process Hazard Analysis. IIAR has even prepared sample “What If ” questions to help complete this analysis. Does that mean you can lock yourself in a room and ll in the IIAR “What If ” questions and then le the results in your PSM / RMP books? No. ere are many requirements (criteria) in the regulations on what constitutes a compliant PHA study. is article focuses on the PHA Team. Both EPA and OSHA have criteria coded into their regulations regarding the team: 29 CFR 1910.119 (e ) (4) and 40 CFR Part 68.X67 (d): “ e process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge speci c to the process being evaluated. Also, one member of the team must be knowledgeable in the speci c process hazard analysis methodology being used.” Expertise in engineering and process operations. is is self-explanatory. In general, you want team members to understand basic refrigeration concepts, knowledge of refrigeration equipment and its functions as well as typical operating conditions.

Experience and knowledge specific to the process being evaluated. It is mandatory that at least one person on your team be knowledgeable of YOUR system. is could be a refrigeration operator, technician, or refrigeration contractor who assists with system operations. Knowledgeable in the specific process hazard analysis methodology being used. Whether you elect to complete the PHA in-house or use a consultant, the facilitator shall have credentials documenting that they understand the methodology being used whether you use the International Institute of Ammonia Refrigeration (IIAR) “What If ” questions or another methodology such as the American Institute of Chemical Engineers (AIChE) Hazard and Operability (HAZOP) study methodology which uses guide words to help the team de ne deviations to normal operations. is documentation can be in the form of a resume showing credentials such as schooling, engineering background, RETA certi cation, on-the-job experience, etc. is covers who SHALL attend your PHA study, but if you are going to invest the time and money to conduct this session, who SHOULD attend to get the most out of the meeting? We have all heard the saying that two sets of eyes are better than one. is is why it is recommended to have an employee who works around or near the regulated process (ammonia refrigeration system), but not directly on the process, involved as a PHA team member. is is a way to ensure a fresh perspective; the refrigeration technician does not drive a forkli all day and would not be able to address the potential

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