ACKNOWLEDGEMENT. Board of Directors, International Institute of Ammonia Refrigeration

Transcription

1 ACKNOWLEDGEMENT The success of the 25th Annual Meeting of the International Institute of Ammonia Refrigeration is due to the quality of the technical papers in this volume and the labor of their authors. IIAR expresses its deep appreciation to the authors, reviewers, and editors for their contributions to the ammonia refrigeration industry. Board of Directors, International Institute of Ammonia Refrigeration ABOUT THIS VOLUME IIAR Technical Papers are subjected to rigorous technical peer review. The views expressed in the papers in this volume are those of the authors, not the International Institute of Ammonia Refrigeration. They are not official positions of the Institute and are not officially endorsed. EDITORS Gene Troy, P.E., Technical Director M. Kent Anderson, President International Institute of Ammonia Refrigeration 1110 North Glebe Road Suite 250 Arlington, VA (voice) ( fa) www. iiar. org 2003 IIAR Ammonia Refrigeration Conference Albuquerque, NM

2 Technical Paper #2 Lessons Learned: OSHA PSM Inspection of a Food Processing Plant with an Ammonia Refrigeration System Myron L. Casada, P.E. Daniel L. Machiela ABS Consulting Knoxville, Tennessee Abstract OSHA inspected a food processing plant with an ammonia refrigeration system that was covered by process safety management (PSM) regulations. 7his paper describes some of the lessons learned from the inspection and discusses how these lessons could be pertinent to other ammonia refrigeration facilities. The paper also addresses how to manage PSM inspections to best answer OSHA s questions while still meeting facility objectives IIA R Ammonia Refrigeration Conference, Albuquerque, New Mexico 0 IlAR

3 88 Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Casada, /? /Daniel L Machiela dt! I n trod uct io n This paper reviews an OSHA inspection of a food processing plant that was subject to OSHA process safety management (PSM) regulations because of its ammonia refrigeration system. (OSHA, 1992) The facility had recently experienced an employee fatality from an industrial vehicle accident, which did not involve the ammonia refrigeration system. OSHA responded to the fatality by conducting a general health and safety inspection using local OSHA office personnel. The local OSHA office then brought in an OSHA inspection team from the Salt Lake Technical Center to perform a three-day PSM inspection related to the facility s ammonia refrigeration system. An outside consulting firm had conducted some PSM training for selected personnel. However, they had not provided any PSM consulting assistance to the facility or visited any of the company s facilities that had ammonia refrigeration systems. Their role during the inspection was to: Help the facility answer OSHA s questions as positively as possible Provide input into the abatement activities that might be needed to address the compliance issues that OSHA personnel identified Provide additional recommendations that would help the facility personnel strengthen the facility s PSM program and ensure safe ammonia refrigeration system operation This paper describes some of the results of the inspection that could be pertinent to other ammonia refrigeration facilities. The facility that was inspected has approved its release. Technical Paper #2 0 IlAR

4 iiar, 2003 IIAR Ammonia Refrigeration Conference, Albuquerque, New Mexico Process Background The facility was in operation before the PSM regulation came into effect. However, the ammonia refrigeration system had been upgraded in 1999 and 2000, when many vessels and most of the piping were replaced. Because of the upgrade, the facility had adequate process safety information (at least for the new equipment) and new drawings. Also, activities associated with EPA s risk management program (RMP) rule 40 CFR 68 (EPA, 1994) focused attention on PSM compliance activities in These activities resulted in adding a PSM coordinator for the facility about six months prior to the inspection. These two circumstances resulted in a great deal of improvement in the ammonia refrigeration system PSM activities. Inspection Results Summary The OSHA inspection team complimented the amount of effort the facility personnel had put into PSM in such a short period of time. However, it noted that the facility should have been in compliance with PSM for several years before that time. The team was particularly critical of the lack of compliance (or failure to document compliance) with industry codes and standards. The OSHA inspectors stated that they did not identify any imminent danger situations. However, they suggested that the facility plan how to respond to the expected citations and how to perform the abatement efforts that would be required. This paper outlines the general recommendations provided to the facility and issues for each PSM element based on: What citations the OSHA inspectors stated they were going to prepare Other issues mentioned by the OSHA inspectors Issues noted by the outside consultant 52 0 llar 2003 Technical Paper #2

5 .. Lessons Learned OSHA PSM Inspection of a F$od Processing Plant - Myron L Casada, ElDaniel L Machiela dr> Please note that the potential citations mentioned in this paper and the associated PSM activities evaluated by OSHA were based on OSHA's view of what the PSM standard requires employers to do. Sometimes OSHA states or infers that "...xyz must be done..." or 'I... the PSM standard requires you to have a specific document..." when the standard may not explicitly require "xyz to be done" or call for a particular document. The PSM standard is performance-based, and some of the interpretations by OSHA and by PSM practitioners, may not be universally held. This paper does not judge the quality of OSHA's decisions. The examples in this paper are simply meant to show you what OSHA's expectations may be if its inspectors were to visit your ammonia refrigeration facility. General Recommendations A recommendation was made to the facility to invest the time required to understand and implement the guidelines provided in ANSI/IIAR-2 and IIAR's bulletins. The facility had only recently obtained the IIAR Standard and bulletins and needed to update the PSM program to address the IIAR recommendations. IIAR's documents describe "recognized and generally accepted good engineering practices. " That language appears in the PSM information requirements [PSM (d) (3) ($3 and mechanical integrity requirements [PSM (j) (4) (ii)]. Additionally, the plant needed to strengthen its understanding of the other engineering codes on which the design of the ammonia refrigeration systems is generally based &e., ASME B&PV Code, 2001; ANSI/ASHRAE-15, 2001; ANSI/IIAR-2, 1999). In the exit meeting, the OSHA inspection team indicated that compliance with IIAR guidelines was required under those provisions of the PSM. Because citations are expected in this area, it was recommended that this be addressed as a high-priority item. Technical Paper #2 0 IlAR

6 In addition, a suggestion was made to develop a strong written description of the facility s PSM program, in addition to using the documents developed by IIAR (which are described on IIAR s Web site at Not only would this allow outsiders to recognize all of the PSM-related activities that the facility undertakes, but the development of such a written program would also allow the plant staff to achieve consensus regarding how PSM requirements would be met at the facility and to develop an action plan for meeting those requirements. Finally, the program could be used as an effective training and reference tool for plant employees and contractors. The facility was provided with specific comments on the written program that currently exists and recommendations for available industry-specific PSM resources. A recommendation was also made for the facility to become familiar with OSHA s Web site, which has a substantial amount of information regarding ammonia refrigeration system safety. Because of previous regulatory actions that resulted in corporate settlement agreements, OSHA has accumulated a great deal of information pertinent to ammonia refrigeration systems and PSM compliance, which it provides at PSM Element Issues In the remainder of this paper, issues from the OSHA inspection are organized by PSM element. If the issue is one that OSHA personnel indicated would be a potential citation, it is so noted. Employee Participation The OSHA inspectors did not raise any issues regarding employee participation IlAR 2003 Technical Paper #2

7 ww Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Casada, /? /Daniel L Machiela iim Process Safety Information Potential citation. The OSHA inspectors indicated that the facility needed to develop a listing of materials of construction for all of the process equipment (including piping and fittings) [PSM (d) (3) (i) (A)]. The information was not readily available for the older equipment in the system. Typically, this information can be provided effectively by a combination of information on the piping and instrumentation diagrams (P&IDs) and equipment data sheets. Unfortunately, the plant did not have these documents updated for the older equipment and piping systems. One of the OSHA inspector s concerns was the potential for galvanic currentinduced corrosion when dissimilar metals are used in a refrigeration system. OSHA publishes a bulletin on its Web site that addresses this specific issue at html. This bulletin describes a release from an ammonia refrigeration system caused by failure of a cast iron fitting installed in a carbon steel piping system. Although many older refrigeration systems have long and successful experience with a variety of piping materials, the issue was important to the OSHA inspectors because OSHA was involved in the investigation described in the bulletin. Potential citation. The OSHA inspectors indicated that the facility must have a document showing the adequacy of the relief valve vent header for all design basis relief scenarios [PSM (d) (3) (i) (D)]. There were no specific relief valve problems identified, and the largest relief valves had l-inch outlet lines connected to a 4-inch relief header. However, OSHA personnel wanted an engineering document that specifically stated the basis for the relief header design. Potential citation. The OSHA inspectors indicated that the facility must have a document showing the adequacy of the machinery room ventilation Technical Paper #2 0 IlAR

8 iicii: 2003 IlAR Ammonia Refrigeration Conference, Albuquerque, New Mexico [PSM (d) (3) (i) (E)]. The facility and its engineering contractor had been working on it, but that effort was not yet complete. OSHA personnel wanted the facility to provide specific documentation that addresses the pertinent IIAR recommendations for the ventilation (IIAR Bulletin 111, 1991).. Potential citation. The OSHA inspectors indicated that the facility needed to ensure and document that all PSM-covered equipment meets recognized and generally accepted good engineering practices. [PSM (d) (3) (ii)] Examples of issues the OSHA inspectors were concerned about included: Pressure relief valve discharge locations Makeup air for machinery room ventilation Adequacy of exits for all machinery rooms Accessibility of emergency isolation valves Provision of power to the machinery room ventilation system that is not deenergized by the emergency shutdown system for the compressors The facility was advised that it is important to ensure that all cases of noncompliance with codes and standards are identified and corrected in accordance with good engineering practices. The facility cannot assume that the OSHA inspectors found all of the issues that need to be addressed. The codes, standards, and practices that required attention included the ASME Boiler and Pressure Vessel Code, the ANSI piping and refrigeration standards, and the related IIAR bulletins (see references). Process Hazard Analysis (PHA) Potential citation. OSHA personnel stated that because all of the process safety information (e.g., updated P&IDs, documented safe operating limits, materials of 56 0 IlAR 2003 Technical Paper #2

9 .. Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Qsada, PEJDaniel L Machiela dx construction) was not available at the time of the inspection, they would conclude that all of it was not available prior to the PHA [PSM (d)]. The OSHA inspectors indicated that the PHA should be updated when all of the required process safety information is available. The OSHA inspectors also indicated that they expected a PHA team to review all equipment to ensure that it meets recognized and generally accepted good engineering practices. Assigning a PHA team to review all equipment for compliance with codes and standards is not a task most companies generally assign PHA teams to perform. It is usually a compliance audit task or is performed during inspections that are part of the mechanical integrity program. Potential citation. OSHA personnel indicated that the PHA documentation failed to indicate that the PHA team adequately addressed the following issues [PSM (e) (3)]: Hazards of the operation (e.g., all operating tasks, including operations such as ammonia unloading and oil draining) Engineering issues (e.g., materials of construction, stress corrosion cracking, water content of the ammonia) Engineering controls (e.g., ammonia detection system, ventilation system operation) The facility could cover these issues by reviewing and implementing IIAR recommendations (IIAR-2, 1999; IIAR bulletins). However, the PHA should be upgraded to address specific operations. Other issues would have been addressed if the PHA team had documented generic and specific safeguards in the PHA report. It was also suggested that the facility consider having a PHA team perform a hazard review of operating procedures once the procedures are upgraded to include all ammonia-related operations. Technical Paper #2 0 IlAR

10 Operating Procedures Potential citation. OSHA personnel indicated that operating procedures should be developed for all operator tasks related to the ammonia refrigeration system (e.g., draining the oil separators, monitoring/operating the automatic purger) [PSM (f) (1) (i)]. Potential citation. OSHA personnel indicated that the facility should ensure that the operating procedures provide steps for monitoring normal ventilation system operation and responding to ventilation system upsets (e.g., how to respond to a high concentration of ammonia in the operating areas, how to respond to loss of ventilation flow) [PSM (f) (1) (i), (ii), (iii) (B), and (iii) (C)]. In industry practice, some of these issues are addressed in emergency response procedures rather than in operating procedures, depending on the facility s approach for training and equipping its personnel. For example, does the staff use fixed or handheld ammonia sensors? Are on-site personnel fully equipped for emergency response or do they rely on offsite response organizations? Potential citation. OSHA personnel indicated that the facility operating procedures did not provide adequate information regarding safety and health considerations [PSM (f) (1) (iii) (A)] and safety systems (e.g., interlocks, detectors, and alarms) [PSM (f)(l)(iv)]. For example, they were concerned that the operators were not clear on when respirators, self-contained breathing apparatus, and chemical protective clothing would be necessary. OSHA personnel were also concerned that the facility personnel did not understand flammability issues for ammonia/oil mixtures IlAR 2003 Technical Paper #2

11 Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Casada, /? /Daniel L Machiela.. 'Itaining Potential citation. OSHA personnel indicated that the facility has not adequately verified and documented that employees have understood ammonia-related training (e.g., operating procedure training). They suggested that the facility staff: Develop a list of required training for an operator to become qualified as a refrigeration system operator Develop training materials to be used for each training topic Provide training for each operator Document the training, including the means used by the facility to ve1 employee's understanding of the training [ (g)] The training documentation issue is likely to be the basis for an OSHA citation. Potential citation. The OSHA inspectors indicated that the facility has not included all of the IIAR information in the training program for the ammonia system operators. Specific issues the OSHA inspectors mentioned were: Safe refrigeration system operations (ANSI/IIAR and IIAR Bulletin 110, 1993) Mechanical integrity (ANSI/IIAR , ANSI/ASHRAE , and IIAR Bulletin 109, 1998) Thermal shock or overpressure (IIAR Bulletin 116, 1992) Pre-startup considerations (IIAR Bulletin 107, 1997; and Bulletin 110, 1993) Technical Paper #2 0 IlAR

12 iiae 2003 IIAR Ammonia Refrigeration Conference, Albuquerque, New Mexico A recommendation was made to the facility that it include these issues in its review effort and incorporate appropriate material into operating procedures and operator training materials. Contractors OSHA personnel took the contractor safety information provided by the facility but gave no indication of their opinion regarding the facility s approach. They did not mention any contractor issues in the exit meeting. Management of Change and Pre-startup Safety Review Potential citation. OSHA indicated that it would propose citation (s) for inadequate management of change and pre-startup safety reviews for the ammonia refrigeration system modifications. OSHA personnel indicated that they were looking for efforts that satisfied both the PSM requirements [PSM (i) and (l)] and the pertinent industry recommendations (eg, the IIAR PSM/RMP guidance). OSHA personnel also indicated that the facility should perform retroactive management of change and pre-startup safety reviews of the ammonia system changes to confirm that all pertinent requirements were met, and then document the results of those reviews. To help resolve OSHA s concerns, it was suggested that the facility request its refrigeration design and construction contractor to document the specific codes and standards that the refrigeration system startup satisfied after the modifications were made. For example, depending on how the modifications were made and how the system was operating at the time, the startup activities might have needed to address two of IIAR s guidance documents: Bulletin 107: Guidelines for Suggested Safety and Operating Procedures When Making Refigeration Plant Tie-ins, IlAR 2003 Technical Paper #2

13 Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Casada, /?./Daniel L Machiela iak, Bulletin 110: Guidelines for Start-up, Inspection and Maintenance of Ammonia Mechanical Refngeration Systems, 1993 Mechanical Integrity Potential citation. OSHA personnel indicated they would prepare a citation related to the regulatory requirement written procedures to maintain the ongoing mechanical integrity of process equipment [PSM (j) (2)]. They indicated that the procedures can be a combination of the facility procedures and manufacturers information (e.g., technical manuals) and should address repair and replacement activities for all process equipment activities that the facility personnel will perform. If contractors will perform the efforts, the OSHA inspectors indicated that the facility should require them to use procedures that meet applicable codes, standards, and manufacturer recommendations. Potential citation. OSHA personnel indicated they would prepare a citation related to failure to perform and document all appropriate inspections, tests, and preventive maintenance activities for ammonia equipment [DSM (j) (4)]. Examples noted were testing of the emergency shutdown system, the ammonia detectors, the ammonia system alarms and cutouts (i.e., interlocks), and ammonia piping. In addition, they referenced the IIAR recommendation for an independent person to periodically inspect the ammonia refrigeration systems. The OSHA inspectors also noted a need to test modified equipment prior to returning it to service. Hot Work Permit There was no discussion of hot work activities. The OSHA inspectors took copies of related documentation. Technical Paper #2 0 IlAR

14 IIae 2003 IlAR Ammonia Refrigeration Conference, Albuquerque, New Mexico Incident Investigation There was no discussion of incident investigation activities. The OSHA inspectors took copies of related documentation. Emergency Planning and Response The OSHA inspectors took a copy of the emergency response plan, but wanted much of the information that the facility has put in the emergency response plan to be provided to the operators as part of the operating procedures (e.g., how to respond to ammonia leaks). Regardless of where the information is placed, procedures need to be developed consistent with the IIAR guidance, and then the operators and other plant staff will need to be trained in the new procedures. Compliance Audits The OSHA inspectors took copies of previous compliance audits and follow-up documentation. They did not discuss any audit issues in the exit meeting. Zhzdk Secrets No issues related to trade secrets were discussed in the exit meeting. The facility has documented that there are no trade secrets related to the ammonia refrigeration process, and the OSHA inspectors showed no interest in the area IlAR 2003 Technical Paper #2

15 .. Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Gsada, PE/Daniel L Machiela de\ Lessons Learned for Future OSHA Inspections Do Not Ignore Pertinent Standards When there are codes, standards, or guidelines that OSHA believes you should meet, you must address them directly rather than ignoring them. This does not mean that you have to redesign your plant per the requirements of every new standard that is issued or whenever existing standards are revised. However, if you are going to handle ammonia (or other hazardous substances), you should stay aware of changes in your industry. If a standard is issued, you need to decide if it has requirements or recommendations that you need to address for safety purposes. You should document the action you took to review it and what (if any) changes you made. OSHA has reflected this requirement in the process safety information language [PSM 29 CFR (d)(3)(ii and iii)] and demonstrated during inspections that you need to take it seriously. Manage the Inspection Scope You may require OSHA to define the scope of the inspection beforehand and then work to get them to stick to that scope. This can minimize wasted time and reduce the involvement of inspectors in areas that are not pertinent. Be Familiar with OSHA's Inspection Procedures OSHA's Field Inspection Reference Manual and compliance policy letters provide specific instructions for OSHA inspectors to follow. Your familiarity with these documents can help you make sure OSHA personnel follow their own requirements. In this specific inspection, the OSHA personnel began using videotape equipment with an audio track that recorded employee voices, without following the pertinent OSHA inspection procedures, e.g., requesting permission notifying all personnel to Technical Paper #2 0 IlAR

16 iicw 2003 IlAR Ammonia Refrigeration Conference, Albuquerque, New Mexico be filmed/recorded. The plant produced the requirements of the appropriate OSHA policy letter and an agreement was reached about videotaping the facility. Control Documentation OSHA inspectors should always be provided with the documentation they specifically request. If they indicate that the documentation provided is not adequate and the plant has other documentation that can help demonstrate compliance, that information should be offered. However, facility staff should not allow OSHA to prospect in the facility files. Facility staff should control access to the files and provide the specific documents to OSHA for review. Keep Rack of Which Records Are Reviewed and Copied The plant needs to keep a detailed log of all records reviewed by the OSHA inspection team and know which records OSHA inspectors copied. In several cases, it has been possible to (1) refer OSHA personnel to documentation they already had to point out information they missed; or (2) identify records they did not review that demonstrated compliance. Both of these tasks are easier if you know exactly what the inspectors reviewed and copied. Keep the Relationship Professwnal Making sure that your staff accepts the inspection as a business activity and not a personal attack is important to maintaining a professional relationship with the inspection team. A good working relationship does not mean that you offer information that is not requested, but rather that you encourage cooperation among your staff and treat the inspection team with respect. If you do so, you will find that the OSHA inspectors will do likewise IlAR 2003 Technical Paper #2

17 Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Gsada, RE./Daniel L Machiela.. References Codes and Standards ASHRAE. ANSI,ASHRAE Standard Safety Standard for Refngeration Systems. American Society of Heating, Refrigerating and Air Conditioning Engineers, Inc. (ASHRAE) ASME. Boiler and Pressure Vessel Code: Section VIII, Pressure Vessels. American Society of Mechanical Engineers (ASME) ASME. Boiler and Pressure Vessel Code: Section V, Nondestructive Examination. American Society of Mechanical Engineers (ASME) ASME. Refngeration Piping and Heat Pansfer Components Code, B31.5. American Society of Mechanical Engineers (ASME) EPA. Risk Management Program regulation, 40 CFR Part 68. Environmental Protection Agency (EPA) IIAR. ANSI/IIAR 2: Equipment, Design, and Installation of Ammonia Mechanical Refngerating Systems. International Institute of Ammonia Refrigeration OSHA. Process Safety Management regulation, 29 CFR Occupational Safety and Health Administration (OSHA) IlAR Bulletins IIAR. Bulletin 107: Guidelines for: Suggested Safety and Operating Procedures When Making Refngeration Plant Tie-Ins. International Institute of Ammonia Refrigeration Technical Paper #2 0 IlAR

18 liar, 2003 MAR Ammonia Refrigeration Conference, Albuquerque, New Mexico IIAR. Bulletin 108: Guidelines for: Water Contamination in Ammonia Refngeration Systems. International Institute of Ammonia Refrigeration IIAR. Bulletin 109: Guidelines for: IIAR Minimum Safety Criteria for a Safe Ammonia Refngeration System. International Institute of Ammonia Refrigeration IIAR. Bulletin 11 0: Guidelines for: Start-up, Inspection and Maintenance of Ammonia Mechanical Refngerating Systems. International Institute of Ammonia Refrigeration IIAR. Bulletin 111: Guidelines for: Ammonia Machinery Room Ventilation. International Institute of Ammonia Refrigeration IIAR. Bulletin 11 2: Guidelines for: Ammonia Machine y Room Design. International Institute of Ammonia Refrigeration IIAR. Bulletin 11 4: Guidelines for: Identification of Ammonia Refngeration Piping and System Components. International Institute of Ammonia Refrigeration IIAR. Bulletin 11 6: Guidelines for: Avoiding Component Failure in Industrial Refngeration Systems Caused by Abnormal Pressure or Shock. International Institute of Ammonia Refrigeration IlAR 2003 Technical Paper #2

19 Lessons Learned: OSHA PSM Inspection of a Food hocessing Plant - Myron L Ghsada, PWDaniel L Machiela iiae Notes:...Q...M...l Technical Paper #2 0 IlAR

20 iiae 2003 IIAR Ammonia Refrigeration Conference, Albuquerque, New Mexico Notes:...b...;......q IlAR 2003 Technical Paper #2

21 88 Lessons Learned: OSHA PSM Inspection of a Food Processing Plant - Myron L Casada,!?E/Daniel L Machiela Ilar Notes: ,......,......,,...,..., Technical Paper #2 0 IlAR