In today’s PodCast Jeremy Williams interview Andre Patenaude whom is the Director of CO2 Business Development through Emerson Climate Technologies. Today we discused topics that are becoming more and more relevant to commercial refrigeration (Natural Refrigerants).

Donated cut-aways to GCAP from Emerson Climate Technologies

This podcast includes discussion of the proposed early phase outs of R-134a and some similar refrigerants by January 2016.

Emerson CO2 compressors for sub-critical application and transcritical applications.

Getting Back to Basics for technicians

University of Dayton Ohio “Global Innovation Center”

GCAP’s CO2 Technician Course

Mobile training simulators for CO2 applications

[youtube width=”480″ height=”320″]http://www.youtube.com/watch?v=hHsQu4c2OiU[/youtube]

Today’s PodCast, Jeremy Williams and instructors of Garden City Ammonia Program talk about the top 3 questions asked in PSM courses through out the year.  Usually many difficult question are asked during class, although some of the simplest questions may be the most difficult to implement.

PSM word for thought in 2013:  If PSM training or process training is viewed only as an event, it will ultimately lead to failure of the program.

1. How do we inform all employees that PSM exists?
2. How do I organize my PSM program?
3. What about PSM Software?

GCAP has had the privilege to be in many facilities for both training and compliance services.  Please feel free to listen to today’s podcast addressing how we have seen it done best.

Thank you all for your support in 2013, We wish you all a Merry Christmas and a Happy New Year.

Don’t forget about the 2014 PSM/RMP Training Tour

GCAP is always looking to improve our PSM training program and consultation services. One of the tools we use is to request information from OSHA and the EPA under the Federal “Freedom of Information Act” which is often referred to as a FOIA request. In 2012 (at great expense) we used this tool to get the citation information for all PSM citations from 2008-2011. In 2013 we filed additional FOIA’s to get all 2012 citations. We don’t just get the citations themselves, but the documents behind them that show the reasoning behind the citations including pictures, the inspector’s inspection narrative, etc. Obviously, we learned a lot about how OSHA and the EPA interpret the PSM/RMP standards  from these FOIA’s and we’ve used that information in our custom textbook for our PSM class as well as source/working material for our NEP class.

Earlier this year, due to a FOIA we read an inspector quote from OSHA course book “3430 – Advanced Process Safety Management in the Chemical Industries.” We’ve long known of this course, but it’s only available from the OSHA Training Institute and only allows OSHA inspectors to attend the class. The quoted line that drew our attention was this: “The loss of Ml due to external corrosion is the single biggest concern in industrial ammonia refrigeration components.”

We wondered – if OSHA is saying this in the course, what else are they saying? What was their source for this information? We again requested to be able to attend the course at our own cost and were turned down.  GCAP’s  recalled a court ruling that was referenced in the MEER decision (http://www.oshrc.gov/decisions/html_1997/95-0341.html) from the 1990’s from the Fifth Circuit Court of Appeals in Diamond Roofing v. OSHRC, 528 F.2d 645, 649 (5th Cir. 1976):

“An employer, however, is entitled to fair notice in dealing with his government. Like other statutes and regulations which allow monetary penalties against those who violate them, an occupational safety and health standard must give an employer fair warning of the conduct it prohibits or requires, and it must provide a reasonably clear standard of culpability to circumscribe the discretion of the enforcing authority and its agents….

If a violation of a regulation subjects private parties to criminal or civil sanctions, a regulation cannot be construed to mean what an agency intended but did not adequately express.”

We didn’t think that an OSHA course on how they interpret the standard could be refused under FOIA so we requested the coursebook from the course under the Freedom of Information Act. Jeremy Williams, Managing Director of GCAP stated: “They can’t rig the game like this – if we’re being held to certain standards, we should know what they are. Sure, this is a legal issue, but at the end of the day it’s about Process Safety – Safety being the key word here.”

Eventually OSHA approved our FOIA request and we received three books totaling about 500 pages.

Unfortunately, they had redacted quite a bit of the information we were actually interested in. One example is the Ammonia Refrigeration Processes and Equipment presentation which was of particular interest.

Slides that were redacted include titles like:

• Does PSM Apply?
• What About NH3 Refrigeration Processes < 10,000lbs?
• What are Signs of a Poor NH3 Refrigeration PSM Program?
• What Design Codes and Standards Could be Expected in PSI?
• Inspection RAGAGEP?

You can understand why we would want access to that information. OSHA had redacted it under provision 7(e) of the Freedom of Information Act. Provision 7(e) protects records or information compiled for law enforcement purposes the release of which could reasonably be expected to disclose techniques and procedures for law enforcement investigations or prosecutions. Essentially, they are arguing that if we knew what they were looking for we would be able to avoid citations.

Look, we at GCAP don’t necessarily disagree in that argument, but this same argument could be made to block any information requested about any citation at all! If they are looking for things because those things indicate a safety issue, then solving those things would alleviate the safety issue. Isn’t that what they are in business for? We don’t think citations should be the primary business that OSHA is in!

We’d rather have the problem solved by the PSM practitioner and refrigeration technicians to ensure the safety of the community and the employee BEFORE the odd OSHA inspection or chemical release. OSHA’s position seems to be that the information on these slides shows inspectors where there are gaps in a program but that information should only be known to the inspectors – not the people actually endangered by the process or the people in charge of ensuring its safety.

Is OSHA more interested in citations than employee safety? It certainly shouldn’t be – according to their own website (https://www.osha.gov/about.html) the reason that congress created OSHA was “to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”

Is hiding information that would show those operating a chemical process where there might be flaws in that process really how they intend to “assure safe and healthful working conditions for working men and women”? We at GCAP don’t think that’s right and we intend to appeal these redactions.

Look for an upcoming podcast where we discuss what we learned from the information they did provide including the answer to the original question: What was the source of that quote in the original citation?

Ammonia PSM Slides OSHA 3430

Randy and Jeremy Williams of Garden City Ammonia Program, discuss one way to test the high level float of an ammonia refrigeration system.  GCAP believes this is a critical test and must be performed part of the mechanical integrity portion of PSM/RMP requirements.

GCAP would also like to thank everyone involved in making 2012 GCAP’s best year.  Next year we are celebrating our 10 year Reunion.  We wish you all a Merry Christmas and a successful 2013.

Brought to you by Garden City Ammonia Program

GCAP Compliance Audits: 2012 Lessons Learned

Garden City Ammonia Program has conducted close to 50 PSM/RMP compliance audits in 2012.   We have learned a mass of information and continue to drive excellence in the ammonia refrigeration field.  According the the EPA’s RMP submissions there are over 14,000 RMP facilities across the US that use one or more of the 140 chemicals that would require a PSM/RMP program.  Over 7,500 of those happen to have ammonia over the 10,000# threshold.

GCAP’s PSM/RMP book is back from the printing press.  It is titled “Implementing Process Safety Management for Ammonia Refrigeration” It can be acquired by taking one of GCAP’s PSM/RMP courses or may be purchased for $895.00  for more information give us a call at 620-271-0037.

The following is the Top 6 Findings  across the Ammonia Refrigeration Industry.

Have your ever asked yourself these questions about your PSM/RMP program.

Who? What? When? Where? Why? And How?

If your not, OSHA and EPA will.

1.  Who are the officials responsible for developing and implementing each of the program elements? Example Management System

2.  What are the requirements and contents of each program element? Example Guidelines

3.  When are the required actions for each element completed and when are they required to be completed?

4.  Where have actions been implemented or changed?

5.  Why have the implementation decisions and priorities been made as recorded in the PSM documentation?

6.  How is the program implemented and how is the program’s effectiveness  evaluated and improved (monitoring performance, follow up and closure of outstanding items, etc.)?

Brought to you by Garden City Ammonia Program

Jeremy Williams of GCAP interviews Rollie Shook and David Binder.  Rollie is currently Chairman at National TRANSCAER(R) Task Group Global Emergency Services Leader at Dow Chemical and North America Emergency Services & Security Associate Director at Dow Chemical.  David is currently Director, Quality, Safety & Regulatory Affairs at Tanner Industries.  We talk about the TRANSCAER’S Anhydrous Ammonia Training Tour and free videos and powerpoints specifically to ammonia.  TRANSCAER is also putting on free ammonia safety seminars across the United States.

If you have not visited their website and viewed this information GCAP is a proud supporter of their material.  Please click on the their logo below to access their great information.

Jeremy Williams of GCAP interviews Gary Smith of ASTI (Ammonia Safety and Training Institute) about the importance of ammonia safety days and scheduled events for 2012.
ASTI has also created many different levels of sponsorship for the national and local level to support this great cause.  ASTI SPONSORSHIP LEVELS

GCAP will host their 4th Annual Ammonia Safety Day May 11, 2012 at Kansas City, Kansas.  Must pre-register to guarantee a seat and they are filling fast.

GCAP’s Ammonia Safety Day

May 11, 2012 in Kansas City, KS

Agenda Below: REGISTER BY CLICKING HERE

Other Safety Days across the United States for 2012 are:

April 11 @ Greensboro, NC

April 13 @ Elkton, VA

April 19 @ Ocala, FL

April 27 @ Atlanta, GA

May 11 @ Kansas City, KS

May 21 @ Springdale, AR

July 12 @ Louisville, KY

October 4 or 10 @ Lancaster, PA

TBD Buffalo, NY
TBD Baltimore, MD
TBD Las Vegas, NV
TBD Denver, CO
TBD Norfolk, VA
TBD Oakland, CA
TBD Houston, Dallas, and Fortworth, TX
TBD South Carolina

ASTI SPONSORSHIP LEVELS

Controlled Liquid Ammonia Release: 1″ Line @ 100 PSIG

[youtube width=”480″ height=”320″]http://www.youtube.com/watch?v=_EJA_Zi5nB0[/youtube]

CHEMNEP

OSHA’s National Emphasis Program CHEMNEP is now the mandatory inspection process of all chemical facilities including ammonia refrigeration.  GCAP has several podcast dedicated to NEP and NEP Citations.  This podcast Jeremy Williams and staff of  Garden City Ammonia Program discuss with Max Lindsay of COMPSM issues arising in NEP inspections across the US.

To read the directive CPL 03-00-014 click here.

3 words of the day.

Documentation, Documentation, Documentation!!!!

Implementation, Implementation, Implementation!!!!

Mitigation, Mitigation, Mitigation!!!!

If you have any question or comments please give us a call: 620.271.0037

If you would like to get hold of Max:
757.876. 7070
www.COMPSM.com
max@compsm.com

This podcast was brought to you by GCAPCoolCast: Division of Garden City Ammonia Program

www.AmmoniaTraining.com

Ammonia21.com

Hydrocarbons21.com

R744.com

“Everything Natural”

Jeremy Williams of GCAP interview Marc Chasserot.  Marc is the Editor in Chief of these natural refrigerant websites.  Marc has over 10 years experience in following natural refrigerants throughout the world and his head quarters are based in Brussels Belgium.   We will discuss in this interview several topics relating to natural refrigerants including the past, present, and future.   Please listen to the podcast to learn more about natural refrigerants and how they are playing a great role in the future in industrial, commercial, and residential refrigeration.

Some topics include:

What countries are taking the lead in refrigeration?
Who is adapting to these changes?
What is the future growth of these refrigerants?
What are some of the best conventions to attend globally?
Small Charge Systems?

A new convention  is coming to the United States during April 2012 in the Washington DC  area.  It will be called “Atmosphere America” and this convention will host anything about natural refrigerants.

United States Chemical Safety Board “CSB”

Jeremy and Randy Williams of Garden City Ammonia Program discuss the CSB findings of a propane explosion in 2007.  Some factors to blame was unqualified technicians, unqualified training and inadequate training for when things may go wrong such as an emergency.  We will compare their findings and recommendations to the industrial ammonia refrigeration industry.

The CSB is an independent federal agency charged with investigating industrial chemical accidents. Headquartered in Washington, DC, the agency’s board members are appointed by the President and confirmed by the Senate.

The CSB conducts root cause investigations of chemical accidents at fixed industrial facilities. Root causes are usually deficiencies in safety management systems, but can be any factor that would have prevented the accident if that factor had not occurred. Other accident causes often involve equipment failures, human errors, unforeseen chemical reactions or other hazards. The agency does not issue fines or citations, but does make recommendations to plants, regulatory agencies such as the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA), industry organizations, and labor groups. Congress designed the CSB to be non-regulatory and independent of other agencies so that its investigations might, where appropriate, review the effectiveness of regulations and regulatory enforcement.

The CSB investigative staff includes chemical and mechanical engineers, industrial safety experts, and other specialists with experience in the private and public sectors. Many investigators have years of chemical industry experience.

Both accident investigations and hazard investigations lead to new safety recommendations, which are the Board’s principal tool for achieving positive change. Recommendations are issued to government agencies, companies, trade associations, labor unions, and other groups. Implementation of each safety recommendation is tracked and monitored by CSB staff. When recommended actions have been completed satisfactorily, the recommendation may be closed by a Board vote.

The CSB is currently investigating several ammonia accidents and deaths.

For more information on the CSB please visit their website at

http://www.csb.gov/

To request CSB’s free Safety DVD of incident investigations visit

http://www.csb.gov/videoroom/videorequest.aspx

Half an Hour to Tragedy Propane Explosion Video Below

[youtube]http://www.youtube.com/watch?v=JzdnUZReoLM[/youtube]