WSU-TFREC/Postharvest Information Network/Process Safety Management: Compliance of Refrigeration Plants
Process Safety Management: Compliance of Refrigeration Plants
Introduction
Any process which involves a flammable liquid or gas on site in one location, in a quantity of 10,000 pounds or more must comply to these regulations. This includes NH3 Ammonia Controlled Atmosphere Warehouse Facilities, candidates for WISHA inspections. It is OSHA Legislated, WISHA Regulated and managed by the Division of Industrial Safety and Health.
The PSM Compliance Requirements
This is a written plan of action by employer implementing employee participation. The employer must consult with employees to conduct and develop a process hazards analysis. Employees should be provided access to all required information. They have a "Right to Know."
Process safety information
Requires information pertaining to the hazards of the
hazardous chemicals in the process; i.e., toxicity, exposure
limits, physical data, reactivity, chemical data. This
includes the technology of the process; i.e., flow diagram,
inventory, limits for temperatures, pressures, flows,
evaluation of dangerous deviations. It also includes
documenting any equipment in the process; i.e., materials,
P&D's, Piping and Instrumentation, electrical,
ventilation, valves, etc.
Process hazard analyses
Employers shall perform a hazard evaluation on processes
while using the following methods:
- What-If Checklist
- Hazard and Operability Study (HAZOP)
- Failure Mode and Effects (FMEA) Fault Tree Analysis
Operating procedures
Employers shall include written operating instructions;
updated annually, to address the following: Steps for each
operation phase; Operating Limits; Safety and health
considerations; Safety systems and their functions.
Training programs
Each employee presently involved in operating a process
shall be trained in an overview of the process and in the
operating procedures as specified. Refresher training shall
be provided at least every three years, and more often if
necessary, to each employee involved in operating a
process.
There must be some means taken by the employer to determine if employees have understood their training. This could include the administration of a written test, although the standard does not require a formal written test. Other means of determining comprehension of the training, such as on-the-job training, etc., are acceptable, as long as they are adequately documented.
Contractor procedures
Contractor procedure requirements applies to contractors
performing maintenance or repair, major renovation, or
specialty work to a covered process. The employer is
responsible for the contractor's safety, work practices,
employee injury and illness log. The contract Employer is
responsible that each employee is trained in the work
practices necessary to safely perform his/her job.
Pre-startup safety reviews
The employer shall perform a safety review for new
and/or modified facilities to include:
- Equipment in accordance with design specifications
- Safety, operating, maintenance, and emergency procedures in place
- Process hazard analysis performed
- Training of each employee completed.
Mechanical integrity procedures
Mechanical integrity includes inspecting and testing
pressure vessels, storage tanks, relief and ventilation
systems, emergency shutdown, controls, and pumps. This also
includes written procedures, training for process
maintenance, inspection and testing, correcting equipment
deficiencies, and quality assurance.
Hot work permit
The employer shall issue a hot work permit for hot work
operation conducted on or near a covered process. It shall
document that fire prevention and protection have been
implemented. It shall be kept on file until completion of
the hot work operations.
Management of change procedures
This requires written procedures to manage changes to
process chemical, technology, equipment, and procedures
that affect a covered process. It shall include basis for
change, impact on safety, modifications to operating
procedures, time for change, and authorization. Employees
shall be trained on changes affecting the process.
Incident investigation procedures
An investigation shall be instigated of each chemical
release which resulted in, or could have reasonably
resulted, in a catastrophic release of chemicals in the
workplace. It shall be initiated promptly as possible, but
not longer that 48 hours. A complete report shall be
prepared including date of incident, description,
contributing factors, and recommendations and review with
affected personnel.
Emergency planning and response procedures
Each employer shall establish and implement an emergency
action plan for the entire plant and its employees. The
Plan shall also include procedures for handling small
releases. Employers may be subject to the hazardous waste
and emergency response provisions at state level.
Compliance audits
Employers shall certify that they have evaluated their
compliance of the PSM provisions at least every 3 years,
and that the procedures and practices developed are
adequate and being followed. The compliance audit shall be
conducted by at least one person knowledgeable of the
process. A report of the audit shall be developed with most
recent reports retained.
PSM Compliance Methods
- Hire a contractor or consultant
- Join (IIAR) International Institute of Ammonia Refrigeration
- Join (RETA) Refrigeration Engineers and Technicians Association
- Get a college degree or certificate
- Documented on-the-job Training
- In-house training programs
- Attend seminars and/or conferences
Where to Get More Information
- Go to other training sessions and classes and document it appropriately
- Read books, articles, electronic sources
- Hire a contractor or consultant
- Contact your local "Labor and Industries" WISHA-OSHA Office
- Contact IIAR
- Contact your local RETA Chapter
- Contact your local fire department
Greg Jourdan
Wenatchee Valley College Refrigeration Technology Department
13th Annual Postharvest Conference
March 1997