INCORPORATING COLD CHAIN

CONTRIBUTORS

can agree with quite a lot of your concerns , but it must be appreciated that safety is not negotiable as prescribed by the OHS Act . It ’ s the law and there is no getting away with it .

OHS Act stands for ‘ Occupational , Health and Safety ’, not ‘ Occupational Health and Security ’, as so many sites seem to think . Let there be a serious incident and the DOL will be all over you and if found to be negligent and non-compliant , the managing director can be found liable and due for prosecution . Not a nice place to find oneself .

So how do we protect ourselves and become compliant ? Firstly , in South Africa as mentioned we need to comply with the OHS Act and all of its sub-regulations such as SANS 10147 , the Pressure Equipment Regulations and all other applicable standards . Sometimes this can be a bit confusing , and let ’ s face it - most of us are not lawyers and more and more it would seem that we need to be .

I have recently become involved in undertaking a “ what if ” process hazardous assessment ( PHA ) of a few sites for all ammonia system components utilising the International Institute for Ammonia

By Andrew Perks

Refrigeration ( IIAR ) standard “ what-if ” ammonia worksheets , as modified by the PHA team .

The philosophy used is to look at a component / assembly in the system and discuss what if something went wrong , are you addressing this in your standard operating procedures , and what would you change to ensure that your procedures are safe .

I first did one of these some two years ago and I must say it is a time-consuming procedure which at the end illustrated some serious short comings on behalf of the client , the installation and the contractor servicing the system .

Along with the “ what-if ” assessment , a failure mode and effect analysis ( FMEA ) was adopted . It is interesting to look at the ( IIAR ) standards available - I tend to use them as a go-to standard when I feel that our SANS 10147 doesn ’ t fully cover the subject .

At the end of the day the “ what-if ” analysis generates a colour matrix that varies from

• Red – immediate response required

• Yellow – a response within the next three months is required , and

• Green – assess again in the next audit The outcome is extremely useful as it lays a path for ongoing improvements and awareness and that there are issues which need to become part of the company ethos .

At the end of the day , it all comes down to people – they are your biggest risk in any plant with hazardous material . We can develop the best systems with all the correct standard operating procedures but without staff with the correct equipment and PPE who are being adequately and continually trained , the outcome is unpredictable .

Talking about IIAR , for those who don ’ t know of them they are the leading experts in the ammonia industry . I have been a member for some time , and I would suggest that anyone who is serious about ammonia standards and concepts should join . They really are setting the standards in the industry .

Talking of standards , they have recently published their latest standard ANSI / IIAR Standard – 6:2019 Standard for Inspection , Testing and Maintenance of Closed-Circuit Ammonia Refrigeration Systems . You might

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 .

ask , ‘ So what ’ s new ? We have known about that for some time .’ Previous standards were suggestive , not prescriptive . Terms like ‘ we suggest ’ have been modified to ‘ it is recommended ’. In the US these standards are adopted by the appropriate bodies and if you don ’ t follow them , you could be in a lot of trouble .

I have mentioned before that the DOL is training up inspectors , so if you are found to be non-compliant , watch out .

Stay safe until next time ! CLA