RACA Journal January 2019 | Page 72

Back to basics 3. of this regulation, that local government shall make prior arrangements with a neighbouring local government, relevant provincial government or the employer, self-employed person, and user for assistance. All off-site emergency plans to be followed outside the premises of the installation or part of the installation classified as a major hazard installation shall be the responsibility of the local government. As can be seen from the above, should you not notify the local authority with regard to an MHI, the owner of the property can be held liable for the damage caused, as it is a legal requirement to notify the local authority. The responsibility of off-site emergency is transferred from the property owner to the local authority in the event of an emergency. 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. A case in point is the Burgundy Estate development next to the crude oil facility in Richwood, Cape Town. SFF has made it clear that there is a clearance zone around the depot and the City of Cape Town and the Burgundy development have been trying for years to get this exclusion zone lifted but without the blessing of SFF, it is not going to happen, explains Thackwary. 70 RACA Journal I January 2019 All that being said, it should be appreciated that the MHI Regulations are currently under review and it is expected that all facilities that have hazardous material will be classed as MHIs. The question will be, to what level? The proposal is that there will be three levels as follows: • Level 1: A plant that is in legal conformity with regulations; that is, SANS 10147. • Level 2: A plant that is in the process of coming into conformity with legal requirements. • Level 3: A plant that is a major risk. The biggest risk will always be the human factor: plant operators. Site training such as Ammonia Site Incident Response is a good way to ensure that any site is prepared and ready for an incident. It really is the only way to ensure that things do not get out of control, as they can — in an instant — if you are not prepared. We will get back into the International Institute of Refrigeration (IIR) material on the role and applications of refrigeration, as I still have much to share with you on that subject. RACA www.hvacronline.co.za