When developing new projects involving flammable substances, reviewing various chemical safety regulations for applicability early in the design process is important. Otherwise, technical studies and safety documentation requirements could delay project permitting and approval.
For example, climate change drives the need for alternative, low-carbon fuels such as hydrogen. Hydrogen production and storage facilities with more than 10,000 pounds on-site must comply with regulations such as:
Best Practices for RMP and PSM Compliance
First, SCS Engineers (SCS) reviews federal and state chemical safety regulations for any exemptions that may apply, including:
SCS then develops RMP, PSM, and state-compliant prevention programs as required for:
SCS recommends conducting a Hazard and Operability Study (HAZOP) for the PHA based on the American Institute of Chemical Engineers (AIChE) HAZOP Guide Word method. Guide words specify deviations from normal operating conditions or parameters and spark discussion of engineering controls, administrative controls, and emergency procedures.
In addition, SCS recommends using multiple safety checklists to review human factors, external events (including facility siting), and potential emergency planning and response procedure changes.
Where safety is lacking or needs improvement, SCS focuses on identifying appropriate mitigation measures. SCS then uses the PHA results to conduct the Hazard Assessment / Offsite Consequence Analysis for the worst-case and alternative flammable release scenarios resulting in fire or explosion.
About the Author: Dr. Lemaster is a Senior Project Manager at SCS. Dr. Lemaster is responsible for the documentation of Process Safety Management Programs (PSM), Risk Management Programs (RMP), and California Accidental Release Prevention Programs (CalARP) projects for regulated facilities using hazardous materials. She has a Bachelor’s Degree in Chemical Engineering and a Master’s and PhD in Nanoengineering from the University of California, San Diego. Contact her at or on LinkedIn.
Additional Resource: Risk Management Plans-RMP and Process Safety Management-PSM
Providing a safe work environment is always essential, but never more so than now. Meeting PSM/RMP compliance deadlines, providing ammonia refrigeration operator training, and maintaining critical safety systems are key components in a safe work environment for facility employees.
Safety systems, such as ammonia leak detection systems, must remain operational as required under the following regulatory criteria:
• OSHA 29 CFR 5189, Process Safety Management (PSM) Section (j)(2)(C) Mechanical Integrity
• EPA’s 40 CFR Part 68, Risk Management Program (RMP) Part 68.73
• EPA General Duty Clause
• RAGAGEP – IIAR Standard 6
These criteria require companies to comply with the manufacturer’s recommendations for maintenance and calibration of ammonia detection systems. Calibrating ammonia sensors on a frequency determined in these same recommendations keeps your business compliant. We all know that compliance is non-negotiable as the ammonia detection system is a life-safety device.
Dedicating itself to providing a variety of online training and virtual meetings, the SCS Tracer Environmental team ensures your systems meet all regulatory obligations. When site visits are necessary; our teams and your facility members use a CDC-based safety protocol meeting state and local requirements, and facility requirements.
For assistance with ammonia sensor calibrations, please contact Mark Carlyle.
In this time of pandemics and stay-at-home orders across the country, much thought has been given to the concept of doing more work remotely. As employees have been required to work from home, the popularity of various business collaboration platforms, such as Zoom, has exploded. As businesses have come to rely on these platforms to continue their essential activities, the idea of utilizing these platforms to conduct remote PSM/RMP activities such as process hazard analyses (PHAs) for our ammonia refrigeration and other highly hazardous chemical processes has grown to a fever pitch.
There are many arguments in favor of a remote PHA. First, it allows us to safely maintain social distancing as required with the current state of emergency due to COVID-19. Second, it allows for more team members to participate while avoiding travel time and costs.
While the first argument supporting remote PHAs cannot be disputed, the reduction in travel costs is often offset by the added time that is required to conduct a thorough PHA over business collaboration video conferencing. There are often technical glitches with the computers or video conferencing platforms that need to be dealt with throughout the PHA. Correcting these issues consumes valuable time, time that is still needed for the discussion of the hazards of the process.
Another time factor that comes into play when conducting a PHA through video conferencing is “Zoom Fatigue.” “Zoom Fatigue” is real. It is challenging to remain focused and engaged in a video conference for more than about six hours at a time. This requires more days to complete the PHA properly. An argument against this six-hour limit is to simply “take more breaks.” While taking more breaks is certainly an option, meeting over a remote platform makes it difficult, if not impossible, to corral team members and get them back on task. In addition to trying to corral team members from breaks, an online platform makes the team members extremely susceptible to the desire to multi-task. More often than not, attendees are involved in checking and responding to emails, answering phone calls, or even addressing in-person issues when on a video/conference call, instead of giving full attention to the task at hand. This makes team engagement difficult and dramatically reduces the effectiveness, and hence the quality, of the PHA.
Team member engagement is driven by the facilitator. Most facilitators rely on eye contact, body movement, and voice inflection to help keep the team members engaged in the discussion. This is difficult at best over a video link. It is downright impossible if any of the team members do not have a video connection and only participate in an audio connection.
Sharing of documents and information is more time consuming using a remote platform. First, any documents that are not in an electronic format must be scanned in order for the team to look at them. Often a scanner is not available or cannot handle the physical size of the document. This leads to attempts to share the document using cell phone cameras. This method is time-consuming at best and often unreadable at worst. Second, it is often impossible due to screen size and resolution to look at multiple documents simultaneously over a video link. When the team is gathered around a conference room table, they can very quickly scan multiple large drawings and collaborate on interpreting them.
It is necessary for the team members to understand the basics of the methodology being used to conduct the PHA. This is why at least one team member must be knowledgeable in the methodology, so that they may guide the team. This guidance is more difficult for the facilitator to provide, given the reduced engagement experienced over a video link. It is often difficult for the facilitator to identify a look of confusion, frustration, or boredom over a video link. It is much easier to do so when sitting across from each other at a conference table.
Finally, perhaps the biggest pitfall associated with a remote PHA is the loss of the ability to take “field trips.” Often, when discussing a hazard or failure scenario, there is ambiguity in the documentation, and memories are vague. When conducting a PHA on site, the team can get up from the table and walk out and look at the area in question. With a remote PHA, this capability is lost. If someone from the site is participating via the remote video link, they could go out and take photos of the area in question and come back and share them with the team. This is not ideal since often pictures don’t tell the whole story, and things may be missed if people only see the picture.
PHAs conducted remotely over a video conferencing link are a viable option for certain types of PHAs. For instance, when conducting a limited scope PHA for a change being conducted under Management of Change, a remote PHA may be a good option. This would depend upon the quality of the available documents supporting the proposed change. When a PHA is being revalidated, and the previous PHA had not been cited for deficiencies in its conduct, a remote PHA may be a good option, providing that a portion of the team members who are knowledgeable of the process being analyzed took part in the previous PHA.
There are many instances where a facility should think long and hard about the potential pitfalls of conducting a process hazard analysis over a remote video conferencing link. If the facility has no existing PHA, if the previous PHA methodology and level of thoroughness were cited by regulators, or if the proposed PHA team consists of few members who took part in the previous PHA, then an on-site PHA should be strongly considered.
About the Author: Bill Lape is a Project Director for SCS’s Risk Management Group in our SCS Tracer Environmental Division. His expertise is in the development and deployment of standardized Risk Management and Process Safety Management (PSM) Programs, including process safety program implementation and PSM support to manufacturing facilities that utilize ammonia as a refrigerant. Prior to joining SCS, he served as Director of EHS Programs and Compliance for Dean Foods where he directed a team of professionals who provided PSM/RMP support, as well as support for stormwater, wastewater, and air permitting at the company’s facilities.
No airplanes, trains, buses, taxis, or Uber required.
SCS Engineers has been working diligently these past few weeks to bring online training to you. With our Tracer team’s dedication, we are excited to let you know, SCS is offering these online classes:
Use our online program to safeguard your operators’ continued compliance education for Process Safety Management and Risk Management Program regulations.
Check out the classes here and register to reserve your spot with one of our in-house RETA Authorized Instructors (RAI).
Do Tracer Environmental professionals ever slow down? The SCS Tracer professionals at SCS Engineers were busy publishing new articles last month in addition to Operator Training. We’ve compiled several of them along with the most popular in our SCS library for your convenience. Select a title and start reading. Enjoy!
How to Properly Complete an IIAR 6 System Safety Inspection Checklist Form? When filling out the ANSI/IIAR 6-2019 Ammonia Refrigeration Safety Inspection Checklists, located in appendix B, some of the information required may not always be readily accessible. This comprehensive article takes readers step-by-step through the process.
Epic Fails, Part Deux Failures that come together, form a picture. The author discusses how we can begin to learn from these Epic Fails and start to take steps to prevent them in our plants.
Ammonia Pipe and Equipment Labeling – Part I Recognized and Generally Accepted Good Engineering Practices (RAGEGEP), an overview of many of the standards and guidelines that are relevant to the ammonia refrigeration system labeling, and guidance on how to apply them.
Ammonia Pipe and Equipment Labeling – Part II Options facilities have when choosing their RAGAGEP for pipe and equipment labeling.
It’s All in Your Past, RETA Breeze Investing in the knowledge and development of your personnel is the first step towards making your management system world-class in the safe operation and maintenance of your ammonia refrigeration system.
Employee Training Under PSM/RMP FAQs about designing a training program that is part of your facility’s PSM and RMP programs and provides a defensible position during inspections while ensuring that your facility operators and maintainers perform their jobs safely.
Mechanical Integrity, Documentation Discrepancies Checks, and verification prevent big problems.
Managing Organizational Change: How it Impacts Your Ammonia Refrigeration System During periods of organizational change, we must keep in mind the potential impacts on our facility’s PSM/RMP or ARM programs, and on the operation of the ammonia refrigeration system itself.
PSM/RMP Compliance Audits: Who Should Perform Them? What to look for in an auditor for hire? For starters, more than a consultant familiar with PSM/RMP regulations.
Management of Change: Have We Captured All of the Impacts of a Change? It is vital to ask as many questions as possible regarding equipment changes under consideration. With more information, you may find that the proposed changes could impact safety.
Bill Lape discusses the most frequently asked questions about designing a training program that is part of your facility’s PSM and RMP programs and provides a defensible position during inspections while ensuring that your facility operators and maintainers perform their jobs safely.
Bill tackles all your questions in this article. Set-PSM-RMP-Hut-Hut
Reflection, as a means of self-evaluation of the robustness of your refrigeration management system, is critical to the continuing success of your program.
Proper planning is another vital element of your program. Together, they will help ensure the continuing safety of you, your employees, and the public.
Bill Lape, a Certified Industrial Refrigeration Operator and a member of the National
Board of Directors of RETA is a Project Director for SCS Engineers. In his most recent article, Bill provides advice to use January and early February as a time of reflection and a planning period. We need to look closely at our ammonia refrigeration management programs, be they Process Safety Management (PSM) / Risk Management Plan (RMP) or Ammonia Refrigeration Management (ARM) for facilities with less than 10,000 pounds of
ammonia in their process.
Click to read the article, and thank you for interest in maintaining safety standards.
Process Safety Management, Risk Managment Plans, Ammonia Refrigeration Management information.
SCS Engineers recently added ammonia refrigeration Process Safety Management and Risk Management Program (PSM/RMP) Project Director William Lape to their professional team working with industrial clients. Mr. Lape joins the SCS Tracer Environmental team in the firm’s Minneapolis–St. Paul, Minnesota office.
Lape brings his expertise and established reputation as a plant engineering manager, senior environmental health and safety manager, and as the director of environmental health and safety – Process Safety, at Dean Foods (NYSE: DF). Dean Foods is a multi-billion dollar American food and beverage company, and the largest dairy company in the United States.
Ammonia refrigeration is a well-proven and effective refrigerant. It does require special programs and safety precautions called PSM/RMP. Lape’s education, expertise, and experience qualify him for the SCS team who hold safety and efficiency paramount. His experience includes senior positions in the food processing industry, direct management of facility operations and environmental compliance programs. Lape will support SCS clients with refrigeration and food industry changes and energy conservation initiatives while helping to keep their employees and facilities safe from potential toxicity and flammability events.
Lape is also a regulatory lobbyist for the Ammonia Refrigeration industry and is expert in developing and conducting technical and safety training classes. His process safety expertise includes Management of Change, Mechanical Integrity, Compliance Auditing, Process Hazard Analysis facilitation, and writing Operating Procedures. His experience also includes: developing release scenarios and preparing RMP submissions; operating and maintaining large industrial ammonia refrigeration systems; project management with scope and specification generation, cost estimating, scheduling, project oversight and commissioning.
He is formally educated and degreed from Purdue University, an active member in the Refrigerating Engineers and Technicians Association (RETA), sitting on their Board of Directors, and in the International Institute of Ammonia Refrigeration (IIAR) on both the Code and Standards Committees. He has multiple RETA and IIAR certifications; is CVI Certified for U.S Dept. of Homeland Security CFATS, and trained in RCRA & DOT Hazardous Materials Reporting.
“Bill is supporting SCS’s rapid growth in the Upper Midwest and Central U.S. industrial operations by providing increased safety and efficiencies to our private and government clients,” stated Thomas Rappolt, a vice president at SCS Engineers, and office director of SCS Tracer Environmental. “Our customers in the region and nationally will benefit from his valuable expertise managing the staff and protocol for safe and efficient multi-facility and multi-disciplinary facility needs.”
Welcome to SCS Engineers!
Using a simple example the authors make apparent the importance of understanding a refrigeration system’s actual performance. An energy balance is a very useful tool to do so.
Not only do PSM regulations require that facilities have this in your PSM program, there is real value in understanding a system’s capacities. Operation and efficiency translates to substantial dollar savings every year. Savings that can be reinvested in your facility.
Calculating the total consequences of an unbalance system is more complex, but there are considerable savings running a properly energy balanced refrigeration system. Savings that can fund maintenance needs and avoid postponing timely repairs.
This white paper, presented at the RETA 2017 Conference in Pennsylvania is available in English and Spanish by clicking here.
Learn more about environmental and engineering services for Process Safety Management (PSM), Risk Management Plans (RMP), and ammonia refrigeration safety at SCS Engineers.
As the weather cools it reminds us that Lee Pyle has compiled a series of great articles for the RETA Breeze this year. There’s still another coming soon, but here’s a review of what she’s published in 2016 to date. What else would you expect from the woman who brings ice sculptures to life in Nevada?
Click the links to take you to the article or to share it with others.
The Process Hazard Analysis Study and “Previous Incidents”, RETA Breeze, Jan-Feb 2016
Risk Management Planning – Get Involved!, RETA Breeze, Mar-Apr. 2016
Mechanical Integrity – 40 CFR 68.73 & OSHA 1910.119(j), RETA Breeze, May-Jun 2016
Incorporating RAGAGEP Into Your PSM – RMP, RETA Breeze, Jul-Aug 2016
PSM / RMP Compliance – DHS CSAT 2.0, RETA Breeze, Sep-Oct 2016 Issue
Thanks, Lee!
