Compliance Doesn’t ETY Automatically Mean Safety

Your industrial ammonia refrigeration facility meets all the local, state and federal requirements regarding regulatory compliance, the Process Safety Management program or Risk Management program is up to date, the paperwork has been properly filed and you pass a government inspection.

Does this mean that your facility is safe?

Not necessarily, according to Peter Jordan, senior principal engineer at MBD Risk Management Services, Inc in Pennsylvania. “You can’t rely solely on meeting regulatory compliance and think that the plant is safe,” says Jordan, who serves as a consultant for facilities preparing for PSM audits. “Conversely, the plant can be safe and not meet all the regulatory requirements. That is the conundrum. Facility owners must realize that forgetting one of those aspects puts the facility at peril.”

As an example, Jordan cites an inspection that the Occupational Safety and Health Administration did several years ago at a facility in Texas where the inspector called the facility’s PSM program “one of the finest he’d ever seen.” As he was leaving the facility, the plant experienced an ammonia release. “With that, the plant was suddenly hit with a number of citations,” Jorden says. “So just because a PSM or RMP can withstand the scrutiny of a government audit does not by definition make the facility safe.”

Finding the proper balance between ensuring a safe facility and one that meets regulatory requirements should be the goal of every industrial ammonia refrigeration facility. In order to successfully accomplish that objective, facilities must divide their time and resources properly so that each goal is reached.

“Many times a facility gears its PSM or RMP program to keep inspectors happy, which is important. But sometimes they forget that it’s not all just about paperwork,” Jordan says. “In order to keep the facility safe, you may need to upgrade equipment, spend more time in the field inspecting the equipment, gather and follow-up on input from operators and mechanics, and ensure that appropriate codes and standards are being followed. Don’t fall into the trap of spending all your time on paperwork while neglecting to focus on what is important to operating and maintaining a safe plant.”

Jordan says that when he conducts a compliance audit at a facility, he devotes equal time to reviewing paperwork, touring the facility, and interviewing the key employees. The typical recommendations from the audit include not only action items to improve PSM and RMP documentation, but also action items to upgrade facility equipment to comply with Recommended and Generally Accepted Good Engineering Practices. “It’s not just about collecting records and documentation to meet regulations,” he says. “A facility needs to pay attention to the quality of their program, their equipment and their personnel.”

As an example, Jordan indicated that the goal of a training program should be to produce well-trained operators and mechanics. Having appropriate records which document that operators and mechanics have attended classroom training and passed written tests is important and might be sufficient to satisfy some auditors, but additional work is needed to be sure your personnel are truly qualified to safely operate and maintain the equipment.

“The best training programs I’ve seen are those facilities that provide equal emphasis on classroom training and on-the-job training,” Jordan says.

The on-the-job training often involves pairing a young operator with an experienced “mentor” who can provide instruction on how to conduct rounds, operate and maintain equipment, and shut down the system in an emergency. These facilities have thorough records to document the on-the-job training, often in the form of checklists.

“I’m not sure a written test is always the best way to judge the competence of a refrigeration operator,” Jordan says. “In many respects, I’d prefer that the operator demonstrates that he understood the training by actually carrying out each task under the watchful eye of an experienced operator. The trick is to document these demonstrations.”

Another critical safety measure when looking at your PSM or RMP is the attention to detail given when filling out management of change documentation. “Don’t just fill out a MOC form and check boxes,” Jordan says. “Look deeper into the change and understand why the questions on the form are being asked. Let’s say you made a change involving the installation of a new compressor in the engine room. Don’t just check the box that says the ventilation is not affected. Installing a new compressor should force you to review the temperature control ventilation calculations. Going through these steps carefully will help make your plant safer.”

Finally, don’t forget to review the basic requirements of a PSM and RMP with facility owners and managers. By educating facility owners and managers, they will then be knowledgeable enough to ask the right questions regarding the PSM or RMP and how it relates to the facility, Jordan explains.

“That training is very helpful so that a facility manager understands the risks and the issues that are involved,” he says. “Paying attention to these details makes the facility safer.”