RACA Journal January 2019 | Page 71

Back to basics 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. WHY ARE AMMONIA REFRIGERATION SYSTEMS CLASSED AS MHIs? By Andrew Perks We take a look at Major Hazard Installation (MHI) Regulations and the legal requirements for ammonia refrigeration plants. I have recently been involved in drawing up emergency plans for quite a few large ammonia plants. What surprises me, is the lack of knowledge about hazards. So, I have broken into my series on the role and application of refrigeration to bring you something on MHI Regulations in an attempt to clear up the legal requirements for ammonia plants. Terence Thackwary of MHR Consultants, an approved authorised inspection authority (AIA) for undertaking MHI plant inspections, replied to my query as follows … 1. 2. 3. According to the OHS Act, the definition of an MHI is as follows: Major hazard installation means an installation: a. where more than the prescribed quantity of any substance is or may be kept, whether permanently or temporarily; or b. where any substance is produced, used, handled, or stored in such a form and quantity that it has the potential to cause a major incident. A site that has been registered as an MHI also has the legal right to determine what developments are done in close proximity to the site. The above definition determines that any refrigeration plant that uses ammonia is considered an MHI and thus means it is subjected to the MHI Regulations, which is part of the OHS Act, explained Thackwary. The Act specifies the following responsibility in terms of who is responsible for when an MHI risk assessment needs to be done: www.hvacronline.co.za Every employer, self-employed person, and user shall notify the chief inspector, provincial director, and relevant local government in writing of: a. the erection of any installation that will be a major hazard installation, prior to commencement of erection thereof; and b. the conversion of any existing installation into a major hazard installation, prior to such conversion. Every employer, self-employed person, and user shall notify the chief inspector, the local government, and the provincial director within 60 days of the promulgation of these regulations of an existing major hazard installation. No employer, self-employed person, and user shall modify an installation by increasing its storage, production capacity, altering the process, or by effecting any other change that may increase the risk of an existing major hazard installation, without notifying the chief inspector, relevant local government, and provincial director in writing. It is imperative that the local authority be notified about the installation or upgrading of an MHI. The local authority has the following duties as per the Act: 1. 2. Without derogating from the provisions of the National Building Regulations and Building Standards Act, 1977 (Act No. 103 of 1977), no local government shall permit the erection of a new major hazard installation at a separation distance less than that which poses a risk to: a. airports; b. neighbouring independent major hazard installations; c. housing and other centres of population; or d. any other similar facility. Provided that the local government shall permit new property development only where there is a separation distance which will not pose a risk in terms of the risk assessment. Provided further that the local government shall prevent any development adjacent to an installation that will result in that installation being declared a major hazard installation. Where a local government does not have facilities available to control a major incident or to comply with the requirements RACA Journal I January 2019 69