By Andrew Perks
Let’s refer to the SANS 1514:2018 Emergency Plan – what makes this so different from what we have had in the past?
One of my clients showed me their emergency plan and it was something like, “Run like hell”. Very funny, but not really a plan. Most new facilities being constructed are required to submit their emergency plan to the fire chief for their perusal. Without it, a certificate of occupancy will not be issued.
The plan itself revolves around a set of organograms which identify key role players in the organisation and their roles in the site emergency team structure. It is a cascade structure that allows for a flow of instructions and information in all directions and defines roles and by definition responsibilities.
Why is it so important? Well, when it is all going pear-shaped you need to know who is responsible for what. Each possible incident is considered on individual pages highlighting the appropriate response; thus, all parties know what to expect from the team in question. Takes away a lot of the confusion in an emergency.
There was an incident in the US where there was a fairly large Ammonia leak on a site but when the emergency services arrived, they could not find anyone who was in command or could tell them what was going on. Total chaos resulting in poor communications and thus an ineffective response to the incident. The client thought that he had it all covered until the event. Of course, that has all been sorted out now, but it could have proven catastrophic in an extreme situation.
One of the main considerations of being ready for any emergency is the yearly site emergency exercise. This is called for in the MHI I spoke of last month. Why yearly? Well, we forget, and there are always new people in the company that need to be trained. Whenever we present our site-incident-response training the client never fails to be amazed at the possible scenarios that could develop and the correct response procedures. One of our concerns is that clients seem to think that an emergency will only involve the refrigeration people.
Hopefully there are SAQCCGas people, so they should know what they are doing – right? Wrong, sure they may know what to do with the refrigeration system, but what about the health and safety people, what about the first aid people, what about the firefighting team and the security people. They all have a role to play and until you draw up the emergency plan the interaction between the teams is not evident. They need to be part of the plan.
“The plan is only as good as the people that know how it works and how to implement it.”
Reminds me of a plan I drew up for a large company in Durban. When you looked at the organograms the one team leader had to be in five different places during an emergency. I think you would agree – not really possible, but it really only became evident when the plan was laid out on paper. But again, the plan is only as good as the people that know how it works and how to implement it. Training, training and more training.
So, we need to have the plan which calls for a command centre where the incident commander is located at all times. As incidents are dependent on wind direction. There should be two command centres just as there should be two assembly areas. In the command centre there should be secure communications, a copy of the emergency plan, and high visibility vests, to name a few items. It really does need to be thought out prior to any incident. I think by now you should be starting to realise why these regulations are so important and while, yes, there is a lot of paperwork, there are reasons for this.
What about the pressure equipment regulation (PER) that is causing such compliance issues? They really are a set of construction regulations where the standards that plant and equipment must conform to is laid out. Remember we are dealing with pressurised systems which have the potential to fail with catastrophic consequences. So, what happens every three years is that the critical components on a system have non-destructive testing (NDT) undertaken to see if there has been any deterioration in the mechanical integrity of components. Relief valves must be re-certified to see that they are within the range of the pressure vessel they are protecting, and corroded pipework inspected.
You probably don’t know that the PER calls for all pressurised systems to be hydrostatically tested every nine years. Can you imagine? All that water in a refrigeration system, makes my hair curl. Well, you can breathe a sigh of relief that we as an industry get special dispensation from the DOL from these nine-yearly pressure tests, but only as long as you are doing risk-based inspections.
So, you might ask, what are risk-based inspections? More stuff to worry about. Well, it really is quite simple to comply with provided you employ a SAQCCGas Cat B technician either on the site or as a contractor. There are a set of schedules as noted in SANS 10147 Annexure G & H which need to be drawn up for your plant and completed by the SAQCCGas Cat B technician and signed off every three months. If you don’t do this the Approved Inspection Authority (AIA) is quite within his rights to demand a nine-yearly pressure test and you don’t want to go there as it would mean removing all the refrigerant, and if you can, get the AIA to accept a pneumatic test – some still want a hydraulic test, filling the system with nitrogen.
This is a nightmare, so it’s best to keep ahead of the situation and do it right first time.
Still lots to chat about next month!
About Andrew Perks
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.