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Substitution Is First Choice
The EPA and OSHA recently issued a joint “alert” to encourage the use of inherently safer technologies (IST) at chemical facilities. The Chemical Safety Alert: Safer Technology and Alternativesis intended to lay the groundwork for a future guidance document by introducing safer technology concepts and general approaches.
According to the Alert, the first choice for managing chemical hazards and risks at a facility is through a Hierarchy of Controls, with the first preference being avoiding hazards by using non-or less-hazardous substances, minimizing the quantity of hazardous substances, or modifying processes to eliminate or reduce the likelihood or severity of incidents.
The alert suggests converting an anhydrous ammonia refrigeration system to a system that uses a less toxic refrigerant, such as glycol and ammonia or an ammonia solution.
Join us for the EPA’s Proposed NAAQS Rule for Ground-Level Ozone webinar on August 13 to identify what the EPA’s proposed rule entails. Register now!
What the EPA Wants You to Know
The EPA has been focusing lately on the prevention of chemical accidents. Here are some lessons the Agency is trying to impart from recent enforcement cases regarding the misuse of anhydrous ammonia.
- Identify the hazards that your facility’s refrigeration systems present by conducting a hazard analysis. Part of the analysis should include understanding the gap between the safety requirements of new industry codes and standards and the standards to which the facility was built and developing a plan to address safety deficiencies. In some cases, that plan must include making facility upgrades.
- Make sure you have a preventive maintenance program. The maintenance program, including inspections, should be documented.
- Gather sufficient information about the piping and equipment so that you understand the hazards associated with your refrigeration system and can develop a proper maintenance program.
- Upgrade refrigeration systems that are missing key controls, such as emergency shutoff valves.
- Make the control of corrosion of pipes and equipment a priority.
EPA’s Proposed NAAQS Rule for Ground-Level Ozone: What It Means and How to Prepare
Register now to learn what to do now to prepare for the EPA’s proposed NAAQS rule for ground-level ozone. Learn more.
- Do not hammer or shake equipment and pipes because it risks breakage and ammonia releases.
- Defrost the system on a regular basis. Ice buildup can impede access to important equipment and dangerously weigh down piping.
- Make sure there is adequate ventilation in a safe location for machinery rooms.
- Be able to shut down the system without entering the machinery room.
- Do not locate ammonia pressure relief devices where they could spray ammonia onto people.
- Ensure that you have a trained operator running your ammonia refrigeration system.
- Maintaining your closed loop system should limit accidents occurring during start-up.