While an ammonia refrigeration system may be beautifully and safely designed, the overall safety of the system is only as good as the employees operating it. The best way to ensure the system is operating safely is to have sound operating procedures (AKA: SOPs). Here is a summary of the SOP requirements found in Title 40 CFR §68.69 and Title 29 CFR §1910.119(f):
The facility must create and implement written operating procedures which provide clear instructions for safely conducting activities involved in each covered process (e.g., ammonia refrigeration system). The procedures should be developed in alignment with the process safety information. These procedures should address (1) steps for each operating phase, (2) operating limits, (3) safety and health considerations, and (4) safety systems and their functions.
The following operating phases need to be addressed:
Initial startup
Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Startup following a turnaround or after an emergency shutdown
Operating limits include descriptions of:
Consequences of deviation
Steps required to correct or avoid deviation
The safety and health considerations should cover:
Properties of, and hazards presented by, the chemical(s) used in the process
Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment (PPE)
Control measures to be taken if physical contact or airborne exposure occurs
Quality control for raw materials and control of hazardous chemical inventory levels
Any special or unique hazards
While the safety systems need to be covered in the SOPs, they also need to be described in your process safety information.
The SOPs must be readily accessible to employees, reviewed regularly to ensure they reflect current operating practice, and certified annually for accuracy. Additionally, safe work practices should be developed and implemented to control hazards during operations, applying to both employees and contractor employees (e.g., lockout/tagout, confined space entry, and respiratory protection programs).
If you need assistance developing or updating your SOPs to be in alignment with these regulations and ANSI/IIAR 7, submit a request through our contact page.
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