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Sunday, March 24, 2019

WSU-TFREC/Postharvest Information Network/Process Safety Management: Compliance of Refrigeration Plants

Process Safety Management: Compliance of Refrigeration Plants


PSM is the proactive identification, evaluation and mitigation or prevention of chemical releases that occur as a result of failures in process, procedures or equipment. The major objective of the PSM regulation is to establish procedures that would protect employees by preventing or minimizing the consequences of accidents involving hazardous materials.

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

Employee participation plan
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:

  1. What-If Checklist
  2. Hazard and Operability Study (HAZOP)
  3. 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:

  1. Equipment in accordance with design specifications
  2. Safety, operating, maintenance, and emergency procedures in place
  3. Process hazard analysis performed
  4. 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

  1. Hire a contractor or consultant
  2. Join (IIAR) International Institute of Ammonia Refrigeration
  3. Join (RETA) Refrigeration Engineers and Technicians Association
  4. Get a college degree or certificate
  5. Documented on-the-job Training
  6. In-house training programs
  7. Attend seminars and/or conferences

Where to Get More Information

  1. Go to other training sessions and classes and document it appropriately
  2. Read books, articles, electronic sources
  3. Hire a contractor or consultant
  4. Contact your local "Labor and Industries" WISHA-OSHA Office
  5. Contact IIAR
  6. Contact your local RETA Chapter
  7. Contact your local fire department

Greg Jourdan

Wenatchee Valley College Refrigeration Technology Department

13th Annual Postharvest Conference
March 1997

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