Cold Link Africa June 2021 | Page 34

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 .
CONTRIBUTORS
INCORPORATING COLD CHAIN

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 .

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

34 www . coldlinkafrica . co . za COLD LINK AFRICA • June 2021