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Home » Why all the legislation concerning our refrigeration systems?

Why all the legislation concerning our refrigeration systems?

By Andrew Perks

I suppose like most people you wonder why we have MHIs, Site Emergency Plans, Pressure Equipment Regulations, SANS 10147… – the list just goes on, and every time we turn around there is another one to worry about.

So much so we actually have to employ someone just to keep up with the regulator requirements. Well, while you ponder on this, it really is not new, but all encapsulated in the Occupational Health and Safety Act. They are all about safety. I would emphasise the word safety – many sites I visit mistakenly seem to think that the ‘S’ in OHS stands for security.

It is a misconception that the ‘S’ in the OHS Act is for security – it is for Safety. Photo by Creative Commons

It is a misconception that the ‘S’ in the OHS Act is for security – it is for Safety. Photo by Creative Commons

Understandably in these troubled times of high unemployment, made worse with Covid, security is a priority, but it must never supersede the safety of employees and the general public. That said, how do these regulations help us?

Everyone should know that the OHS Act is a set of regulations that are laid out to ensure safety in the workplace. Most things we do carry an element of risk, whether it be falling down some stairs or a non-skilled person undertaking a dangerous procedure – we are all exposed to danger in our day-to-day life.

These regulations are set out to protect us in some instances from ourselves by enshrining in law a set of standards that we all should comply with. It would make it easier if we all did, then we would know what we expect the next responsible guy to do in any situation. Sadly, that’s not the case – all you need to do is go for a drive and you will see what I mean.

So, what we get out of these regulations is a need to comply with a defined set of standards – and we do this through training, training, and more training. For you guys out there that know me, you know that training and adding value is my passion. I have good news for you, the younger people that I come across fill me with anticipation: that we have a bunch of people with potential; we just need to lead them in the right direction. We can all help with this.

But let’s start with an MHI. For those who don’t know what that means, it stands for Major Hazardous Installation. In essence any site that has hazardous material could be classed as an MHI if it has the potential to cause a hazardous release or incident. I know the general thought is that this should apply to a very large volume of the hazardous material, but if we consider that the release of a single cylinder of ammonia/freon in a confined space has the potential to asphyxiate and cause death to anyone trapped in the area, this changes one’s perception. So, we need to revisit the term ‘hazardous’.

An MHI looks at a site to evaluate the risks present on the site to the surrounding area and general public, while the OHS Act looks at safety of employees on the site. From general statistics out there, it is an accepted fact that up to 80% of all incidents are caused by people – and that’s the problem. A case in point; if you do not service your car and it breaks down, is it a) mechanical failure or b) human error, I think we will all agree it is the latter.

Only through training and ongoing monitoring can it be said that the ongoing risks at any site can be reduced. This is raised in an MHI, all sites must have an emergency plan. This is not one of those books or manuals you draw up and file away, nor is it a one-page escape plan. It is a living document that you use as a training tool and practise at a minimum once a year. It is a SANS document (SANS 1514:2018), and I can tell you it is a very concise ‘incident by incident’ response procedure document.

Obviously, one of the issues in any emergency plan would be the skills of the responding teams. There recently was a major Ammonia incident where the shortfalls of the emergency plan were evident, allowing the incident to escalate.

It’s not magic, it’s about training and then some more. One of the issues we have found is that the emergency services are ill-equipped to handle any Ammonia release, and where possible we try to include them in any training course that we present. I truly believe that our emergency services are fantastic people putting themselves on the line for us, but Ammonia is something they have little or no experience with.

We really have only touched on the subject of all these regulations, but I will continue in the next issue. In the meantime, stay safe.