By Andrew Perks
These days with the requirement for safety audits for hazardous plants, the need to assist clients to identify non-compliance is paramount.
Ammonia as we all know is a hazardous medium, but that said it still is one of the most versatile refrigerants around. By complying with the regulations, we can ensure that the plant is safe, but not every user is aware of what compliance entails.
Although you have met all the OHS Act regulations applicable there is still the question of plant operation and human error. It is a given statistic that human error accounts for up to 80% of all incidents. Thus, the reason the industry is pushing so hard for more training and up-skilling of artisans.
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Now, human error covers a wide spectrum – not just the plant operator but all the way to the top management. Any piece of equipment we use needs maintenance and if/when for whatever reason this maintenance is not undertaken timeously, and the component fails -would that be classed as mechanical failure or human error? I think not mechanical failure, human error is the issue. Puts a different slant on it doesn’t it?
You may or may not know there is a depreciation allowance on capital equipment, the idea being that some of this capital will be ploughed back into the plant with continuous upgrades, thereby keeping the equipment in good condition. I once worked with an engineer who was of the opinion that annually 10% of the plant’s value should be recycled back into the plant to keep it in a pristine condition. Doesn’t really happen though does it, so many plants operate on the proviso of “if it’s not broken why mess with it”.
I know we all need to make a profit and that’s why we are in business, but it all changes when the depreciation simply becomes a bottom-line tax adjustment figure which is not being recycled into the plant and machinery.
A pre-emptive quality maintenance program is everything when it comes to longevity and reliability of equipment. I know of one fruit cold store complex that fully services all their valve assemblies and equipment, and there is a lot of it, every year in the off season. Sure, it’s a load of work but they say it pays as there are minimal breakdowns during the season resulting in an extremely reliable plant with excellent product temperatures, so that extra bit of TLC really pays off.
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The reason I picked this topic is that I was recently asked if there are any statistics on non-compliance issues with Ammonia plants and what they are. Interesting question, so I thought let me pull out some figures which might surprise you.
I would like to share these with you so let’s look at our latest 9 SANS 10147 Ammonia Plant Audits as follows:
When we do the audit, we check off a priority list from SANS 10147 and gauge the plant compliance against those. Obviously, anything else that is not OHS Act compliant or SANS compliant, we bring to the client’s attention – but these items are a good base indication of the plants condition and compliance.
Major non-compliance issues constitute 28% of the summation with following common issues such as:
- plant not being operated by competent people
- equipment not being secured
- lack of maintenance
- plant operational instructions
- emergency response instructions
- first aid response training
- the correct maintained PPE and people trained on how to use it
- 3 monthly SANS control and equipment inspections, and
- 3 monthly inspection of pressure relief valves for leaks
Less troublesome, but still non-compliant issues constitute 14% of the summation with following common issues:
- fitting of red lined pressure gauges
- extraction fans to be spark proof
- emergency stop buttons
- discharge vent lines of relief valves and ventilation fans not to create a safety issue
- detailed site response procedures to a hazardous release
Items that need attention constitute 16% of the summation with the following common issues:
- expired gas mask canisters
- safety equipment not readily accessible
- ammonia detection
- safety showers and extraction fan controls outside of the plant room
The remaining 42% constitutes minor infractions that need attention but are not critical.
These are figures I have compiled over the past year on plants that are mostly fairly safe with clients trying to maintain a reasonable standard but as you can see over 50% of issues are present.
The issues raised come as quite a shock to most of the clients but it’s that old adage: out of sight – out of mind. They forget that should there be a hazardous release the responsibility can go right the way to the top.
Ignorance of the law is not mitigating circumstance.
Until next time, stay safe.
About Andrew
Andrew Perks is a subject expert in ammonia refrigeration. Since undertaking his apprenticeship in Glasgow in the 1960s he has held positions of contracts engineer, project engineer, refrigeration design engineer, company director for a refrigeration contracting company and eventually owning his own contracting company and low temperature cold store. He is now involved in adding skills to the ammonia industry, is merSETA accredited and has written a variety of unit standards for SAQA that define the levels to be achieved in training in our industry.