In the food and beverage industries, small and large business alike both face grave risks to the health and safety of their employees and facilities, which directly affects progress and profitability. Furthermore, OSHA’s and EPA’s aggressive enforcement actions are reminders of the importance of the specific regulatory requirements surrounding process safety management (PSM) and related programs.
Tony Lundell, director of standards and safety at the International Institute of Ammonia Refrigeration (IIAR), Alexandria, Va., discusses how to maintain process safety in food and beverage plants.
How does the IIAR Suite of Standards fit in with those of OSHA's request for information on PSM?
OSHA’s request for information (RFI) pertaining to the Executive Order 13650 is to collect, review and consider any information that may be lessons learned, best in practice and any methods that could improve chemical facility safety and security. The goal is to modernize the PSM standard.
When OSHA promulgated the PSM standard in 1992, the standard adopted management-system elements based on best practices from the industry at the time. Best practices have continued to evolve since 1992, and additional management-system element may now be recognized to be necessary to protect workers. Since the RFI sought public comment on additional management system elements that would increase worker protection if required under the PSM standard, IIAR reached out to partner organizations to build coalition around the comments that were announced.
The IIAR standards represent the most applicable Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for ammonia refrigeration systems. These IIAR standards should be the primary source material for OSHA inspection officials when inspecting ammonia refrigeration facilities. The facilities shall maintain the flexibility to define their RAGAGEP and update it as necessary. Keep in mind that IIAR bulletins, handbooks and data books that are guidelines are also considered RAGAGEP for the ammonia refrigeration industry.
The IIAR Suite of Standards purpose will also provide OSHA and the EPA, as well as others, a single source of normative enforcement and supportive explanatory informative data for the ammonia and natural refrigerant industry.
Why is it so crucial to continually implement PSM programs when it comes to ammonia refrigeration systems?
PSM provides a matrix of elements, that when implemented, provides operational, maintenance and quality assurance for controlling refrigeration systems. This control helps assure safe and healthful workplaces and indirectly protects the environment.
While focusing on training and safety protocols, it is important to keep contractors engaged and critically thinking. What is the value in assessing both leading and lagging indicators to make sure this is done?
Keeping contractors, as well as employees engaged, allows them to become a quality assurance team member for their own safety and health and for those around them. Always being alert and knowing that suggestions or methods can be considered for improving safety anytime is key. Lagging indicators help identify what facilities may be missing or provide information of what other facilities in the industry are missing. By getting the information of what other sites may have fallen short on helps provide a compelling business reason to consider if facilities of their own need to address the issues. The same goes for leading items. Leading items can identify evolved best in practices that should be considered and implemented if it truly improves and provides protection for personnel and the environment. Energy saving methods have evolved as well that can be considered.
In your position, have you used past OSHA litigation cases to identify risks and prepare for future targets?
Yes. Whenever an unfortunate event occurs in the industry, its information is reviewed to see if it is applicable and then shared with members and/or committee members who are working to continuously improve our material. We also use this information to prepare for any questions that may come our way.
What do you believe attendees will gain at the 2nd Annual Process Safety Conference for Food & Beverage Industries, Aug. 25-27 in Chicago?
I appreciate the networking with others, as well as hearing firsthand what others have to share during their presentations. While giving presentations, any questions asked provides an opportunity for interaction and clarification for all participants. Some topics may be new, while others previously understood have evolved. Staying abreast of the industry as to how it has evolved and how it is still evolving is valuable information and knowledge. When firsthand experiences are shared and allowed to be discussed between the participants, these lessons learned can be taken immediately by the participants, which they can bring back and share with their own facilities. Listening and participating in other’s presentations is exciting and educational. The discussions that occur between the enthusiastic participants during general social times makes it an enjoyable event as well.