[This blog series derives from a technical paper written by Eli Macha, President of Macha PSM]
The Process Hazard Analysis (PHA) is the most important activity related to safely operating a covered process. And when it comes to ammonia refrigeration systems, it is no different. Whether the facility decides to outsource the PHA leadership or conduct the study in-house, there are several ways to optimize the PHA for ammonia refrigeration systems.
While regulators may not always look at every element, they will review each facility’s PHA. If a PSM Coordinator is coming onsite, they should first ensure that a PHA is on file. If there was a change of ownership, the PHA should be completely redone or at least revalidated since many of the safeguards and risk tolerances used in the study may not apply to the new company.[1]
After the PHA has been located or completed, the recommendations must be tracked to completion. While certain states like California require PHA recommendations to be resolved within 2.5 years, the federal PSM and RMP regulations do not specify how long a facility has to resolve PHA recommendations.[2]
Here are two principles to keep in mind:
First, the timetable for recommendations depends on the severity, urgency, and the scope of the change. If it is discovered that the emergency eyewash and shower station in the machinery room is malfunctioning, this should be addressed immediately. However, if there is a recommendation to consider installing an emergency pressure control system, a longer timeframe is understandable.
Second, as a general rule, regulators prefer to see PHA recommendations resolved within one (1) year. Oftentimes this is not feasible, but if forty-five of fifty recommendations have been resolved in the first year and a timetable has been established to resolve the remaining five, most regulators will be amenable.
The mistakes to avoid for PHAs go hand-in-hand with the low-hanging fruit.
Firstly, do not neglect to resolve PHA recommendations. You do not have to do as each recommendation prescribes per se, but each recommendation should have a written resolution. If the facility decides not to act upon a recommendation, sufficient justification should be provided.
Secondly, the other mistake to avoid is forgetting about old PHA reports. While not all regulatory inspections are equally as scrupulous, EPA inspectors routinely ask to review all PHA reports. Not only should past PHA reports be located, but PSM practitioners should check to make sure that all past PHA recommendations have documented resolutions. This is an area that is often missed.
Finally, how does a facility optimize its PHA for ammonia refrigeration systems?
In general, these are two methodologies that are primarily used in this industry:
the what-if/checklist
the hazard and operability study (HazOp)
Certain reputable PSM consulting firms utilize the HazOp methodology because it is inherently more thorough. While this is true, there is a plethora of industry resources and knowledge that cannot be as easily utilized apart from the what-if/checklist methodology. The primary way to elevate a facility’s PHA is to utilize IIAR’s checklist questions. Instead of being relegated to the combined experience of those around the PHA study table, integrating questions from the IIAR’s checklist infuses the study with experience from the entire ammonia refrigeration industry.
[2] Title 19 CCR §5100.2(e)
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