2023 Jul-Aug RETA Breeze

RETA BREEZE

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION JULY/ AUGUST 2023

PREPARING FOR AN RMP / PSM INSPECTION OR AUDIT

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BREEZE

The RETA Breeze is the official publication of the Refrigerating

Engineers & Technicians Association (RETA). RETA is an international not for-profit association whose mission is to enhance the professional development of industrial refrigeration operating and technical engineers. Don Chason Executive Editor 704-455-3551 Jim Barron Executive Director

jim@reta.com Sara Louber Senior Director, Office Operations

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5 Reasons to Attend the RETA 2023 National Conference

INSIDE THIS ISSUE Epic Fails Now Who was Supposed to

sara@reta.com Stephanie Date Events Manager stephanie@reta.com Harry Wilkins Education Coordinator harry@reta.com Dan Denton Chapter Relations Liaison ddenton@reta.com

Message From The President........... 4 Message From the Executive Director............................ 6 Call For Nominations Annual Awards.................................. 8 Conference Corner: 5 Reasons to Attend the RETA 2023 National Conference ............................ 10 Attend a CARO, CIRO, CRST, or CRES Review Course at our 2023 National Conference....................... 12 Education Corner........................... 14 Preparing for an RMP / PSM Inspection or Audit......................... 16

Check That? ........................................ 20 Confined Space?.............................. 22 “Everybody’s Job” is Nobody’s Job................................. 24 RETA Testing Corner No. 37 How RETA Exams Reflect Industrial Refrigeration Industry Standards ........ 25 RETA Certification Exam Applications and Certification Renewal Applications can now be completed online!............................ 28 2023 National Conference Sponsors.............................................29 Certification Honor Roll................ 30

The information in this publication is based on the collective experience of industry engineers and technicians. Although the information is intended to be comprehensive and thorough, it is subject to change. The Refrigerating Engineers & Technicians Association expressly disclaims any warranty of fitness for a particular application, as well as all claims for compensatory, consequential or other damages arising out of or related to the uses of this publication. Publication of advertisements in Breeze , or any other RETA publication, does not constitute endorsement of any products, services or advertisers by RETA and shall not be considered or represented by advertiser as such. Copyright © 2023 Refrigerating Engineers & Technicians Association.

REFRIGERATING ENGINEERS & TECHNICIANS ASSOCIATION 1725 Ferry St. SW, Albany, OR 97322 Telephone: 541.497.2955 | Fax: 541.497.2966 RETA.com

RETA.com 3

2022-23 BOARD OF DIRECTORS CHAIRMAN Keith Harper, CARO Tyson Foods Inc PRESIDENT Bengie Branham, CIRO, RAI SCS Engineers

FROM THE DESK OF THE PRESIDENT

EXECUTIVE VICE PRESIDENT Michael Hawkins, CARO Midatlantic Refrigeration, LLC TREASURER David Gulcynski, CIRO Dot Foods Inc. SECOND VICE PRESIDENT Bill Lape, CARO, CIRO, CRST SCS Engineers DIRECTORS

Greetings My RETA Family,

I am extremely excited to say that this months President Desk is coming to you from South Africa… And yes, I said South Africa. Jim Barron and I are in the country at this time to bring our RETA culture and standards to the international commu nity. The RETA culture coupled with our core “family values” have risen to a point that the global community is aware and very intrigued. They not only view us as the Gold Standard to promoting safe and efficient operation of industrial refrigeration systems, but they are envious that we all coalesce as a family and support each other. What RETA has projected to the international industrial refrigeration world has once again shown that American grit and determi nation can create anything we put our collective minds to. And that is why I am so excited to show the world what RETA is all about. It is an honor to be an ambassador for RETA. With Jim and I having our “family support”, the international industrial refrigeration world is going to get both barrels at one time. Now to be completely honest, I have to disclose that I was very cynical at first when accepting the invitation to bring our RETA values to other countries. But through direct conversation with individuals and now actually being outside the United States, I have a sense of shame. Let me explain. As a proud American “Red, White and Blue”, I looked at everyone through that

Alan Gervais, CARO, CIRO Western Precooling Systems Andrew Palomar, CARO APCCO Arlie Farley, CARO, CIRO, CRST Farley’s SRP Inc Barbara Kirkpatrick Mi-Docs Debbie Koske Calibration Technologies, Inc. Edward Johnson, CARO Gordon Rascoe, Jr, CIRO, CRST, RAI ConAgra Brands Jeremy Murfin AC & R Specialists Jim Kovarik Gamma Graphics Services Melissa Cassell General Refrigeration Company Raymond Urban, CARO Lineage Logistics Victor Dearman, Jr., CIRO, CRST Peco Foods, Inc COMMITTEE CHAIRS Certification: Lee Pyle, CARO SCS Tracer Environmental Education: Eric Girven, CIRO, CRST, RAI SCS Tracer Environmental Marketing: Jodie Rukamp SCS Tracer Environmental Membership: Arlie Farley, CARO, CIRO, CRST Farley’s SRP, Inc National Conference: Jim Kovarik Gamma Graphics Services Publications: Vern Sanderson,

Bengie Branham, RETA National President

prism. Very prideful and stubborn. What I didn’t see through my jaded view was that there is a world that only wants to be what we are. They do not wish to compete with us. They only want the same things that we desire. To provide for their families and to have a better way of life. Last year, while I was in Orlando performing an MI inspection, I met an amazing gentleman that is from the continent of Africa (I will have more on this person and the incredible organiza tion he is associated with in my final Breeze edition). To hear firsthand his personal struggles to come to America and experience the “American Dream” stopped me in my tracks. I began to look inward at myself and what my priorities were at that time. At that moment, what I came to realize, I did not like what that light illuminated in my soul. I was never a bigot and I

CIRO, CRST, RAI Schwan’s Company Executive Director: Jim Barron

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always saw good in people. I did not care about color, race, accent or culture. My belief was that everyone was equal. I only had American Pride. I mean, my beautiful wife immigrated here from Russia and I thought I was a compassionate loving person. But I still had some prideful misunderstandings that where still deep inside my spirit. What I desperately needed and what GOD showed to me was that I needed to have

American compassion. You see, I had forgotten that my family was once in their shoes. My family was once an outcast and discriminated against because they had immigrated and were different. The major ity of the American ancestors were immigrants. They came to this land with the same hope and desire as everyone who enters today. What I did not know at that time in Orlando is how I was being prepared for this moment. This perfect encounter at

the perfect time prepared me for this day was a very humbling encounter to say the least. Thank you, Lord, for softening my soul and preparing me for this journey. The United States, RETA, and all things that God Blesses us as Americans with daily, still projects hope and a promise of a better tomorrow to all in the world.

Exciting times ahead!!! God Bless you all.

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FROM THE DESK OF THE EXECUTIVE DIRECTOR

Good Day RETA Family, I am writing to you today from Cape Town South Africa. Bengie, our RETA National Board President, and I have endured a very long two-day airplane travel to get here. I’m sure to some of you that this is nothing as you do business around the globe. To me it was grueling at best, but well worth the venture. Bengie and I are here for two reasons, one - to participate in Global Cold Chain Alliance South Africa (GCCA SA) this week, and two - to meet with refrigera tion industry people on RETA educa tion, certification and RETA member ship. As I reflect on this it reminds me of our RETA Constitution and By-Laws which is something not done often enough. Here is Article ll – lV. If you get a chance, go to the RETA website and under Governance read the whole Constitution and By-Laws. This is your association, and our members are the RETA owners. ARTICLE II – Purpose Section 1. The purpose of this Association shall be: To further the education, training, and technical knowledge of its Members in the art and sciences of refrigerating engineering and all phases of refrigera tion; to disseminate information concerning refrigeration and refrigera tion engineering; and to engage in, foster and encourage research in the field of refrigeration. Section 2. To advance and foster cooperation and friendly relationships between employers and employees and persons interested or engaged in the business of refrigeration. Section 3. The Association shall have

Coordinator starting after the 1st of September. Mr. Harry Wilkins has moved seamlessly to Education Coordinator and will work with the RAI’s and the Education committees in order to take RETA education to the next level. The National Conference is coming along quite nicely as Stephanie and the team are doing an excellent job. We are looking forward to another great conference with some of the best refrig eration training in the world. AWARD NOMINATIONS NEEDED Remember if you know someone that is an outstanding ambassador for RETA through education, service, leadership, training etc. please nominate them for a RETA award. At this time this is about all I have for you. I will have some news on the South Africa visit in the September/October RETA Breeze. I hope you all are having a great summer! God Bless each and every one of you!

the following powers: To purchase, take, receive, lease as lessee, take by gift, devise or otherwise acquire and to own, hold, use and otherwise deal in and with, any real or personal property or any interest therein, situated in any state or jurisdiction and to sell, convey, mortgage pledge, lease as lessor, and otherwise dispose of all or any part of its property and assets. Section 4. To allow other groups or Associations to affiliate with this Association for the interests and purposes heretofore set forth. ARTICLE III – Motto The motto of this Association shall be: EDUCATION – EF FICIENCY – DEVELOPMENT. ARTICLE IV – Jurisdiction Section 1. The territorial jurisdiction of the Association shall be worldwide. As I move forward, I always keep our Mission Statement and our Constitution and By-Laws in my mind which allows me to always act in the best interest of the Association, and to continue doing the right things for the right reasons for our membership. I do believe that Bengie and I are in South Africa for the right reasons. Expectations of this visit are to be part of the Global Cold Chains event, to bring Africans into our membership and give them the best training and certifications possible for our Industry, and to save lives through training. I do believe these are the right things for the right reasons. We also have some announcements… Samantha Ibarra has been promoted to Certification Coordinator. Moving forward she will work with the team to take care of all certification needs. We have a new Marketing and Sales

Jim Barron RETA Executive Director

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CALL FOR NOMINATIONS - ANNUAL AWARDS

The following awards will be given out at the annual Conference in Jacksonville, Florida this November. They are named in honor of past RETA members who exemplified a specific strength that benefited the RETA membership and our industry either through teaching or leadership or service. Identify who that special RETA person is and jot down some reasons you think they should be honored. Send this nomination and the supporting documentation to the Executive Director Jim Barron by email to jim@ reta.com or submit it online at reta.com/ nominations. Nominations must be received by September 29th, 2023 in order to give the awards committee adequate time to consider the nominations.

Guy R. King Memorial Award

Recognizes outstanding job performances in education and training of members nationally and locally.

Venneman Award

Recognizes an outstanding RETA member for a career marked by leadership and service to the profession and the organization.

Felix Anderson Award

Recognizes two individuals who have worked behind the scenes at the Chapter level and who are not on the national Board.

Elliott R. Hallowell Award

Honors the member whose record of service to RETA for the current year merits special recognition and reward.

Kim Snowden Award

Honors an individual, company, or organization who promotes the furthering of women within the refrigeration industry. This could include, but is not limited to: • Individuals who have promoted women in the refrigeration industry throughout their career; • Individual women, who, by standing out and taking on leadership roles have indirectly inspired other women to pursue careers within this field; or • Companies that have encouraged and provided opportunities for women within their organization.

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CONFERENCE CORNER

5 5 REASONS TO ATTEND THE RETA 2023 NATIONAL CONFERENCE 10 RETA.com

N OT SURE if the RETA 2023 National Conference is ation Industry. You will broaden your professional and personal network connections, receive a deeper understanding, uncover new learnings, and reinforce existing best practices of industrial refrigeration through a vast array of educational and hands-on sessions. And the best part is traveling, having fun and connect ing with the RETA Family! #1 LEVEL UP YOUR NETWORKING Did you know that meeting FACE-TO-FACE builds more meaningful and strong business relationships? According to GreatBusinessSchools, 85% of people believe face-to-face meetings are essential for long-term business relationships. Humans thrive on in-person interaction and the RETA National Conference is the perfect opportunity to expand your network and make connections, find potential new leads, mentors, and collaborators in industrial refrigeration. right for you? Read on! RETA 2023 National Conference represents the best of the best in the Industrial Refriger-

BEWARE OF HOTEL POACHERS

The Hyatt Regency Riverfront Jacksonville is the ONLY contracted hotel for the 2023 RETA National Conference. Room poaching is a practice carried out by third-party companies that act as travel agencies. These poachers may inform you that the hotel room block is sold out or offer a discounted rate. They may even state they represent RETA or use the RETA Logo in their emails. This is not true. We have been made aware of solicita tions to the 2023 RETA National Conference from convention housing bureaus offering reduced hotel rates. These housing companies are known as Hotel Poachers or Hotel Pirates. They are NOT affiliated with the 2023 RETA National Conference or the Hyatt Regency Riverfront Jacksonville. How hotel poachers book rooms and attempt to get your money: Most poaching agencies do not have a contract with any hotels for room blocks they will contact a housing wholesaler, such as Expedia, Priceline, etc. to see if rooms are available that they can mark up to resell to unsus pecting guests. Typically, want your money upfront, paid in full. DON’T BE MISLED! ** There are NO 3rd party housing companies authorized to represent RETA or the Hyatt Regency River front Jacksonville.

#3 MEET INDUSTRY EXPERTS & INFLUENCERS You will meet and listen to numerous experts and influencers within the RETA Family. Building a relationship with these individuals can be incredibly beneficial to your learning and connection. Ask ques tions and receive advice from the best of the best experts in the field. #4 SPEAK OUT ABOUT YOUR BUSINESS The RETA Conference is the perfect platform to speak publicly about your own business or the business you work for. Refining skills, generate interest, all while building your brand and expanding your reputation while in the exhibit hall and networking events. #5 HAVE FUN & TRAVEL! Come eat delicious food, visit a new area, socialize, learn and laugh with like-minded people… like you! Like I said, attending RETA 2023 will not only provide you with an abundance of educational opportunities about diverse and changing aspects of the industry, develop your knowledge while earning PDH, and expand your professional and personal network, you will get your ques tions answered by refrigeration experts, build company branding, have fun along- side hundreds of likeminded people within the Industrial Refrigeration Industry that are worth knowing.

RETA takes networking to the next level. Arrive early to take part in pre-conference activities beginning on Monday, November 13th with our TopGolf Networking Lunch and the Monday Night Out Event at the Autobahn Indoor Raceway. During the conference, plan to network at our two Exhibit Hall Receptions, Jacksonville Icemen Hockey Game, RETA After Hours Lounge, and Sip n Dip. Curious about RETA Chapters, or Women In Natural Refrigera tion (WiNR)? Join our Chapter Leaders Reception and WiNR Networking Happy Hour. And don’t forget to download our mobile conference app to connect with other attendees and exhibitors, access the schedule and floorplans. #2 EARN PDH CREDITS, EXPAND YOUR KNOWLEDGE & SKILLS The best thing about attending the RETA National Conference is the abundance of knowledge offered, making it easy to earn PDH credits. Look for: • Workshops • Specialty Exhibit Hall Sessions • Hands-On Sessions • Technical Topics • Hot Point Sessions • Review Courses

RETA.com 11

compromising the safety or integrity of refrigeration systems. Course includes the RETA Energy Efficiency Handbook. Certified Refrigeration Service Technician (CRST) is designed for technicians and support personnel who troubleshoot and maintain industrial refrigeration plants and facilities. The credential addresses topics from advanced levels of plant safety and oper- ations through the basics of ammonia refrigeration compliance and PSM requirements. A CARO or CIRO credential or at least four years of progressively responsible experience in industrial refrigeration is required. Course includes the Ammonia Refrigeration Compliance Guideline and Industrial Refrigeration III. Train the Trainer Course is focused on training adults in hands-on operations and technical skills and its applica tion is designed to benefit employees that are asked to design and/or deliver training in the workplace. Partici pants identify the learning needs of adults, how to plan, develop, and implement different types of training, and how to deliver and assess the success of the training. Take advantage of the opportunity to sit for the exam following the review course at the Conference while the information is still fresh in your mind. How convenient! RETA certification exams are accredited by ANSI (Ameri can National Standards Institute), which requires that they are continually scrutinized by an organization whose sole mission is to establish, maintain and assure that the highest industry standards are set and met in a continu ous and ongoing basis. ANSI is certainly recognized and often highly regarded by regulatory agencies such as EPA and OSHA in the establishment and maintenance of the highest industrial and safety benchmarks. RETA-certified operators must meet high standards for industrial refrigeration training and knowledge. RETA offers the following credentials and training opportuni ties for refrigeration industry operators and other professionals. A completed online exam application with payment is required. This fee is separate from the review course registration fee and the Conference registration fee. The on-line exam applications are located at https:// reta.com/under the certification tab. Please contact RETA HQ with questions 541-497-2955 or certification@ reta.com. Reservations for exam seats are scheduled in the order the payment is received. Don’t wait! Get your application and payment turned in today! Contact certification@reta.com for more information.

ATTEND A CARO, CIRO, CRST, OR CRES REVIEW COURSE AT OUR 2023 NATIONAL CONFERENCE Each course includes a three-day educational program (November 11-13), handouts/speaker materials, RETA coursebook(s) listed in class description (shipped to you prior to Conference), 24 PDH credits, and a continental breakfast and lunch each day. Certified Assistant Refrigeration Operator (CARO) is designed for new operators who demonstrate entry-level knowledge that qualifies them to work under supervision in industrial plants and facilities. Course includes Industrial Refrigeration I. Certified Industrial Refrigeration Operator (CIRO) is designed to assess more advanced concepts, principles, and applications required to supervise industrial refrigeration operators. A minimum of two year’s machine room experience is required. Course includes Industrial Refrigeration I, Industrial Refrigeration II, and Basic Electricity II. Certified Refrigeration Energy Specialist (CRES) is designed to assess mastery of refrigeration system operations and energy management strategies. While no other RETA credentials are required to qualify for the CRES credential, CRES candidates do need to demonstrate sufficient knowledge of refrigeration operations to offer energy management strategies without

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being the Gold Standard. We must consistently review, revise, and remain ahead of the curve to provide the most accurate detailed material possible. This cannot be accomplished with only one person’s knowledge, experience, or insight. It takes a collective group of like-minded individuals whose goal is to make others safe and successful. I look forward to serving with each of you who are on the Education committee, and I want to thank all of you for dedicating your time, energy, and efforts toward the RETA mission of enhancing the profes sional development of the industries operators, technicians, and engineers alike. If you are not currently part of a committee and find yourself interested in the Education committee, please contact Eric Girven, RETA Education Commit tee Chair at EGirven@scsengineers.com or Harry Wilkins, Education Coordinator at harry@reta.com

I’m very blessed to have a role with RETA and I am extremely excited that the role is now with Educa tion. I had the pleasure of being on the subcommit tee that worked on the latest revision of RETAs IR-III, and I learned quickly that there was a lot I didn’t know, especially regarding writing material, but with the help and expertise of the other committee members we revised a great book. Working for RETA and with the Education commit tee to me is being a part of something so much bigger than yourself or anything one person can accomplish. By dedicating time toward reviewing, revising, and updating our material to meet the industry’s needs, we are changing people’s lives by teaching them how to run systems safely and efficiently. We are truly making this wonderful industry a much better place to work. It’s thanks to RETA and the backbone of RETA, its committees that have made this industry a safe and now lucrative career choice. It’s your commitment to RETA and the industry that has made RETA the Gold Standard in Ammonia Refrigeration Training and will remain that way moving forward. There is a lot of responsibility in

Harry Wilkins, RETA Education Coordinator

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PREPARING FOR AN RMP / PSM INSPECTION OR AUDIT

“By failing to prepare, you are preparing to fail”— Benjamin Franklin Having your Process Safety program audited or inspected can be very stressful. Here are some tips on things you can do to improve your audit results. They break down into three categories: Before, During, and After the audit. BEFORE THE AUDIT You may not have advanced warning of an Audit, but if you have time to prepare you should focus on these three topics: • Know your Program

If your program is well organized and reflects your practices, your next step is to look at all your open recommendations and action items. PHA’s, MOC’s, PSSR’s, Incident Investigations, MI reports, previous Audits, etc. tend to have action items or recommendations. If those aren’t addressed, they can each be turned into audit findings. Realize that you are doing the auditors’ job for them, as each of these recommendations is a finding of non-com pliance or an unsafe condition. “Preparing your staff” is simply allowing the people in your facility to make their own preparations for the audit. Remind them that their answers should be made by referring to the written program, and not recited from memory.

“Knowing your Program” is a large topic. Since a PSM/RMP program is a written program, you need to let it speak for you, and this requires you to know where all your documents are and how can you easily access them. Now that you know your documents are available, are they accurate and consistent? Start with your Management System (where you say who are the Responsible Persons for each PSM/ RMP element) and then work through your individual element written plans. As you get into those written plans, do they accurately reflect what your practices are? For example, if you say you conduct a walkthrough every 8-hrs in your documen tation, can you provide documents of those walkthrough’s occurring on that written schedule?

• Prepare your staff • Prepare the facility

16 RETA.com

• How much ammonia do you have? Go to the inventory calculation. • How do you drain this oil pot? Go to the Operating Procedure. • Who is in charge of the MOC’s? Go to the Management System. You get the idea. Going to the written plans and schedules gives you a consistent answer regardless of who is answer ing the question. Lastly, prepare yourself as the coordinator. Realize that this is a learning opportunity, both for you and for your Process Safety program. If you rely on an outside PSM/RMP consul tant or corporate resource, get them involved NOW before the audit has started! Remember that Process Safety is a Team Sport. Your audit team will include not only your site personnel but any corporate, 3rd-party consultant, and legal resources you have available. “Prepare the Facility” is about doing the last-minute things that show off your facility and your plan in the best light. Plan your site tour route with this in mind. If time permits, do some dusting, painting, labeling, and tagging as needed. A little bit of housekeeping goes a long way in establishing good will. LOOK at your system. A dented drain pan will draw questions about “struck-by hazards.” A fresh weld and unpainted pipe will draw questions about Management of Change and PSSR. If there is some ongoing maintenance or construction, perhaps this would be a good time to have them focus on another facility that isn’t being audited? DURING THE AUDIT It’s important to keep a few guidelines in place during your audit: • Remain Calm • Set the tone early • Keep a paper trail. Take pictures of what they take pictures of. Make copies of every document you provide them. • Ask for clarifications. If there is any confusion, ask for written questions • When in doubt, ask to get back to them. • Answer as briefly as possible • Wherever possible, answer with DOCUMENTS • Close the day and the audit with Thank You. “Remain Calm” is just about your attitude and professionalism during the event. Remember that they are auditing the program and the facility, not YOU personally. You want to keep this event focused on the program, so keep your politics and emotions to yourself. “Setting the Tone” is how you manage the “feel” of the audit. You can set the tone early with how you treat the auditor.

Regardless of how they treat you, treat the inspector as if they are a concerned friend trying to ask you some tough questions. That said: • Only give the minimum information needed to answer the specific question being asked. • Offer facts, not opinions – NEVER LIE TO AN AUDITOR! • Defend your program with every defensible argument, using all your available team resources. Another useful thought for “Setting the Tone” is to welcome the inspector. I know that sounds odd but think through this with me. Are you likely to get a better result if you treat the inspector as an enemy, or if you honestly say “We spend a lot time and resources on our Process Safety program, and are looking forward to finding ways to improve it.”This way of thinking brings the inspector on to your team – as people working together to address issues, rather than as a hostile force trying to tear you, and your program, down. “Keep a paper trail” is about making sure you KNOW what the inspector has. If they take pictures of something, you should take the same picture. If they ask for documents, you need to keep EXACT copies of the documents you provided them. “Asking for Clarification” is making sure you understand the questions being posed to you, including what the inspector

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is actually looking for. It is a good practice (especially if you are not 100% sure) to get questions in writing to facilitate your internal team discussions. “Get back to them” allows you to properly formulate and format your answer. Remember, that questions on the program should be a “team” answer. Some questions are “leading questions” or traps. You may not recognize them, but legal professionals and outside consul tants have probably already experienced them so it’s wise to get their input before responding. Giving yourself a little time to respond allows you to incorporate some of the other tips: • Make your answers brief and to the point. • Whenever possible, answer with program documents. Finally, remember to close the day (and / or the audit) with a “Thank You.”This acknowledges the work of your team, but also helps set the tone with the auditor as they leave to consider what they saw and heard. AFTER THE AUDIT • If you haven’t called for additional resources yet, there is still time. • Follow-up or clarification questions from the auditor must be supplied in writing. • Make copies of every document you provide them. • Attempt to “close the gap” on any issue the inspector has already identified. • Share your results with sister facilities. • Defend your program with every defensible argument. Even if you declined to engage your corporate, 3rd-party consultant, and legal resources earlier in this process (when it would have yielded larger improvements) it’s still not too late! When an auditor asks further follow-up or clarifying questions once they’ve complet

audit without having to experience the pain you just experienced! Lastly, remember to have your team defend your program with every defensible argument – even if you decide to improve that program or its implementation. CONCLUSION Those of us who have experienced multiple inspections and audits have learned some strategies to improve our results. It’s been said that “Wisdom is healed pain” so it would be wise to learn from the pain we’ve already experienced to improve your performance!

ed their initial audit, it’s likely they are on to something. This is why it’s important to get these questions in writing so your entire team can engage for your answers. As before, make sure you keep exact copies of any answers and documents you provide to these questions. Where possible, close the gap of any- thing identified during the audit. Closing the gap shows “good faith” and improves the program as soon as possible. For example, if during the audit a lack of pipe labels was noticed, there’s no good reason not to address that deficiency as soon as possible. Sharing your audit findings, struggles, and improvements can make sure your sister facilities gain the benefit of your

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EPIC FAILS

NOW WHO WAS SUPPOSED TO CHECK THAT? By Bill Lape, SCS Engineers A couple of months ago, a contractor with whom I frequently do business showed me the valve shown to the right. At first glance, it appeared to be a standard gauge/drain valve. However, once I removed the seal cap, it was obvious that something was amiss. Photo #2 provides evidence of that. So, I asked the contractor, “What’s the deal? Why is the bonnet assembly missing from this valve?” He replied, “ That is a really good question. We found that on a section of a system that was being pumped down for maintenance after having been in service for a short period of time.” I said, “You’re joking. This was in a live system? I don’t believe it.” He then showed me Photo #3. Could this have been staged? Sure it could have. Do I trust this contractor? Maybe not if he is buying me drinks, but when it comes to their service work, yes. So, let’s look at how this is an Epic Fail. First, let’s start with the Code of Federal Regulations. Both OSHA’s Process Safety Management (PSM) regulations, found in 29 CFR 1910.119, and EPA’s Chemical

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the operating procedure or refer to them in the operating procedure and develop these checklists independently as part of the PSSR. For instance, the commissioning steps of an evaporator would include, but not be limited to: Bumping the evaporator motors to check rotation; Calibrating the RTD being used to measure the room temperature; Tuning the control loop that controls a motorized expansion valve; Check to make sure that all drain valves are CLOSED AND PLUGGED; Pressure Testing it per ASME B31.5; and Leak Testing it per ASME B31.5. In the case of this valve, the unit was likely not pressure tested in accordance with ASME B31.5. If it was, then my hat is off to the valve manufacturer for making one strong plastic cap. So PSSR failure #1 is a lack of proper commissioning steps in the procedures. Regarding the ensuring that the construction and equipment meets design specifications, if the project is conceived and implemented without thorough, clearly written design specifications, then what do have to check the construction and equipment against? Clearly, a sketch on a cocktail napkin isn’t going to cut it. If you don’t have a design specification, then we have to look to Recognized and Generally Accepted Good Engineering Practice. This starts with the model codes, as adopted at the state or local level. These would be building, fire, mechanical, plumbing, and electrical codes. Then we have to look at the consensus standards that are adopted by the model codes. Examples of these consensus standards include IIAR2, the Standard for the Safe Design of Closed-Circuit Ammonia Refrigeration Systems, or ASME B31.5, the Refrigeration Piping and Heat Transfer Components Code. IIAR4, the Standard for Installation of Closed-Circuit Ammonia Refrigeration Systems, and IIAR5, the Standard for Start-up of

Accident Prevention Provisions, or RMP, found in 40 CFR Part 68, contain sections pertaining to the conduct of Pre-Startup Safety Reviews (PSSR). Both regulations state, in essence, that when modifying a covered process, such as our ammonia refrigeration system, a PSSR is required when the change is significant enough to require a change to the Process Safety Information of the system. The regulations go on to state that the PSSR will, prior to the introduction of ammonia into that section of the process, confirm that the construction (of the change) and the equipment (installed or modified during the change) has been in accordance with the design specifications. The regulations further state that safety, operating, maintenance, and emergency procedures are in place and are adequate. Let’s address the procedures first. One of the requirements under both regulations is the development of operating procedures that includes, among other things, steps required for Initial Startup or the equipment. Most facilities that developed their operating procedures after the installation of the equipment state something along the lines of, “The specific initial startup procedures used when commissioning equipment are not contained in this document. These procedures will be developed on a case-by-case basis following industry (IIAR) guidelines and using the pre-startup safety review procedures.” These operating procedures then lead into the steps for a Normal Startup, which are the steps to take if the equipment has simply been shut down when it has not been needed. This Normal Startup “phase” omits any commissioning steps. While this is fine for existing equipment, when we are expanding our system or replacing old equipment with new equipment, we must include the commissioning steps either in the Initial Startup “phase” of

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Closed-Circuit Ammonia Refrigeration Systems, are also examples of consensus standards with which we must be familiar. PSSR failure #2 is a lack of a design specification, but, more importantly, also a lack of knowledge of the codes and standards upon which a design specification would be based. A Pre-Startup Safety Review is essential to help prevent a catastrophic release of ammonia from our systems. Finding personnel with the required knowledge and giving them time to thoroughly review the system modifications will help to keep your employees, your contractors, and possibly the public, safe. If you have pictures of some Epic Fails from your “Brother-in-law’s” facility, please send them to NH3isB2L@gmail.com. Bill Lape is Project Director for SCS Engineers. Bill is a Certified Industrial Refrigeration Operator, a Certified Refrigeration Service Technician, and a member of the National Board of Directors of the Refrigerating Engineers and Technicians Association.

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CONFINED SPACE? Have you ever seen a bucket classified as a confined space? Why not? There’s only one way in and out, so it has limited means of access and egress. The answer is simple. There’s no way you can enter it bodily. What about the oil separators on your screw compressors—are they designated as Confined Spaces? I have been in many plants where all the compressor oil separators were classified as Confined Spaces. In my opinion, this is a result of confusion about OSHA’s Permit-Required Confined Spaces Standard, 29 CFR 1910.146. The confusion arises when the definition of a Confined Space becomes conflated with the definition of a Confined Space Entry. Most people in industry are familiar with the definition of a Confined Space entry. This is the definition, straight from the OSHA standard: Entry means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.

Let’s look at another definition, straight from the OSHA standard--the definition of a Permit-Required Confined Space (PRCS). A PRCS is a space that meets the OSHA definition of a Confined Space, and: • Contains or has the potential to contain a hazardous atmosphere • Possesses an engulfment potential to someone who enters the space • Has an internal configuration that could cause an entrant to be trapped or asphyxiated • Contains any other recognized serious safety or health hazards Please note that a PRCS must first be a Confined Space. If the space in question does not meet the definition of a Confined Space, then it cannot be a Permit Required Confined Space. So, let’s look at the

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• Finally, let’s take a harder look at the phrase “to perform assigned work”. I have seen 55 gallon drums used as trash cans, and although you could fully enter one, I have never seen one placarded as a Confined Space. At least part of the reason is there is just no work to do in there. So honestly, it you have an oil separator that you could conceivably enter fully (if the coalescer filters were removed) should it be considered a Confined Space when the only assigned work could not be performed if you are in the space? So, what are an employer’s obligations under 29 CFR 1920.146? Step one is the performance of an assessment of the work- place to determine if it contains spaces that meet the OSHA definition of a Permit- Required Confined Space. One of the most common citations under the Confined Space Standard is failure to identify Confined Spaces in the workplace. Step two , the employer must inform affected employees of the existence of all the PRCS’s, their locations and the hazards contained therein. Employee notification can be accomplished as easily as posting appr- opriate signage on PRCS’s. Step three— you must make a decision as to whether you will allow your employees to enter PRCS’s or if you are going to hire contractors to perform any work that must be accomp- lished in a PRCS. If you plan to have your own employees enter PRCS’s, you must develop a written program. That of course is a topic in and of itself, but the standard is explicit and detailed. By the way, have you read the Standard? Once you do, here are some links that are useful in gaining a better understanding of the subject:. https://www.osha.gov/laws-regs/ regulations/standardnumber/1910/1910.1 46#:~:text=Confined%20space%20 means%20a%20space,have%20 limited%20means%20of%20entry. https://www.osha.gov/sites/default/files/ publications/osha3138.pdf https://www.michigan.gov/leo/-/media/ Project/Websites/leo/Documents/MIOSHA/ Fact-Sheets/GISHD/Fact_G019.pdf https://tools.niehs.nih.gov/wetp/public/ Course_download2.cfm?tranid=4372

definition of a Confined Space. OSHA published a booklet in 2004 designated OSHA 3138-01R that goes a long way toward clearing up misconceptions about imple- mentation of a Permit-Required Confined Space policy. So, let’s take a more detailed look at what makes an enclosed space a Confined Space. The OSHA definition of a Confined Space is any space that possesses all three of these characteristics: • It’s large enough and so configured that an employee can bodily enter and perform assigned work. • It has limited or restricted means for entry or exit. • It’s not designed for continuous employee occupancy. We are going to examine each of these of the criteria that define a Confined Space in reverse order. • A concept that is sometimes misunder stood is “designed for continuous occupancy”. The Michigan OSHA (MIOSHA) means that the space could be occupied during normal operations; not that it is continually occupied.” For most of the enclosed spaces we would concern our- selves with, the answer would be no, they are not designed for human occupancy. • Limited or restricted means for access or egress. A door can make a big differ- ence. Not just a door, but a door that can be opened from inside the space. Oil separators don’t have doors. Evap- orative condensers do, but not doors that are operable from inside the space. • To “bodily enter” means that it is possible for an employee’s entire body to enter the space. This is also referred to by OSHA as to “enter fully”. MIOSHA puts it this way: “To ‘bodily enter’ means that it is possible for an employee’s entire body to enter the space. If the space itself is too small, or the opening into the space is not large enough for the entire body to enter, then bodily entry cannot take place; such a space cannot be a confined space.” This is where the bucket doesn’t make the cut—you just can’t get your whole body in there. is helpful with their explanation: “ ‘Continuous employee occupancy’

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