I wonder how many people out there are somewhat mystified with the Major Hazard Installation ( MHI ) Regulations or really understand what they mean – or is it just me ? Well to compound things , the regulations were re-gazetted on 31 January 2023 .
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INCORPORATING COLD CHAIN
Where are we now with the MHI Regulations concerning Ammonia refrigeration systems ? By Andrew Perks
I wonder how many people out there are somewhat mystified with the Major Hazard Installation ( MHI ) Regulations or really understand what they mean – or is it just me ? Well to compound things , the regulations were re-gazetted on 31 January 2023 .
An MHI is defined as an installation where there are hazardous materials stored or processed that could cause a major incident . Up until now there has not really been a definition of the quantity that this would entail . In the latest regulation it has been defined . A low risk is defined as a plant with 15 - 49 tons of Ammonia , a medium risk is defined as a plant with 50 - 199 tons and a high risk is one with over 200 tons of Ammonia . Now that means that almost all of our basic ammonia plants are excluded as they are below the 15-ton threshold , where larger plants such as breweries will be medium risk . So , we ask ourselves what do the MHI regulations actually cover ?
Now we think that only plants with 15 tons of Ammonia are dangerous – A plant in America had approximately 2 500kg . The engine room ignited after an Ammonia leak , destroying the plant room . If it was here , and assuming it was SANS 10147 compliant , it should never have happened . That is also why each and every Ammonia plant must be built to SANS 10147 requirements and have a three-yearly re-assessment by a competent person .
From my experience volumes of less than 15 tons of Ammonia are used in the majority of operations and distribution depots around the country , and that ’ s where the risk is . The problems are the lack of skilled , trained plant operators and non-compliance with SANS 10147 . Some of these plants have never been inspected and work on the principle : “ if it ’ s not broken , why fix it ?” Now , I understand that the current economy is such that some of these plants are on the edge , but it is not good enough if we are looking after the safety of our staff .
Any business operating in South Africa must conform to the OHS Act , which basically refers to safety . Based on this , we have to ensure the safety of workers or the general public – whose health and safety could be affected by any incident of whatever magnitude . That said , this is really not related to quantity but rather to the risk . Let ’ s say there are 10 of us doing some training in a typical office of 20m 2 , and a 63kg bottle of Ammonia is released . What do you think is the likelihood , if the door is locked , that we would survive ? Pretty
Image from Feepik . com low I would say . So , what does that tell us ? Any hazardous incident is related to risk , not quantity . And that doesn ’ t apply only to Ammonia - there are plenty of other hazards out there .
That is why in the MHI regulations ’ tables of quantities governing the level of risks , we also have the clause which states , “ considered a Major Hazard Installation .” Lots of people seem to think that the new regulations now deregulate them from being an MHI with all its constraints and conditions . There are quite a few people who believe this – but they can think again . There has to be a case submitted for each and every plant with hazardous material as to why it should not be defined an MHI . This still requires the services of an Approved Inspection Authority ( AIA ) to justify whether a plant must be registered or whether the material and the type of business on the site dictates that the site is an MHI .
The law is such that all users must conform and comply or face strict consequences if found negligent . Furthermore , you also cannot omit the consequences to your site from an MHI next door . All of this has to be taken into account in your emergency plan .
The Department of Employment and Labour ( DEL ) wants companies to have a good working relationship with the local authority . Should the local authority fail to comply or assist with the above , the DEL will take the local authority to task for not complying to the new regulations . There should be an offsite emergency plan to deal with associated consequences if there is an incident . To facilitate this , the council requires a dedicated contact person with whom sites can interact , assisting with the creating of the plan .
Each site must also have an onsite emergency plan that is approved by the local authority . So as not to confuse anyone , there is a new standard as to what is required in the emergency plan , SANS 1514:2018 . This is a lengthy document which forces sites to look at their command structure and their readiness for any emergency situation . It is amazing the number of sites that think “ it will never happen to me ” and as such , are not prepared . You really only see the glitches when you do the mandatory yearly site incident response exercise .
The site risks are cumulative , based on the number of hazardous / flammable materials on site . Let ’ s face it , there is normally more than just Ammonia - what about diesel , propane , petrol , and more ? All of those delivery vehicles on site at any one time represent risks and need to be accounted for in the report . Any findings will be based on probability , not quantity stored .
Each site must also have an onsite emergency plan that is approved by the local authority .
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 .
The DEL is highly aware that there are a vast majority of installations with hazardous material that have never registered . With the new regulations , there was recently a roadshow travelling around the country which was attended by all the AIAs affected by the regulation change . It ’ s a new regulation so there are still some aspects of it which are not totally clear , but they are working on resolving the issues . So much so that they have appointed 70 additional inspectors in the Western Cape alone . They are clearly taking this seriously .
There are a lot of regulations that the normal operator is not aware of , that is why we use the services of an AIA . Are we aware that there must be an approved competent person appointed to ensure that the ongoing requirements of the report are being applied and conformed with ? This is not a five-yearly exercise that is done then placed into a drawer until it ’ s time to resubmit : it is an ongoing commitment .
What about the three-yearly emergency plan and the annual training . Think of those 73 people that recently died in Johannesburg – what about the gas explosion in the road ?
Just doing an assessment does not cut it . It has to be undertaken within the scope of the regulations , and there are plenty . Not doing anything , claiming ignorance of the law will not help when the managing director is standing in court trying to explain that he did not think this applied to his company . There are so many incidents all around the country . Only by following the correct procedures and applying strict monitoring and control can we keep our people safe .
I trust that this has made you think a bit – we need to develop a culture of safety .
Stay safe until next time . CLA
30 www . coldlinkafrica . co . za COLD LINK AFRICA • November 2023