Advance Food Company - Executive Summary
Advance Food Company, in both its' Enid, Oklahoma and Caryville, Tennessee plants utilizes anhydrous ammonia for its product refrigeration processes. The process technology of ammonia refrigeration systems has been in existence for many years and is therefore standardized and not subject to significant change. Changes in design for the system involve only additions to or modifications of the existing system and its components. The technical design basis for ammonia refrigeration would only be modified by the IIAR, ANSI, ASHRAE, or a similar organization. Therefore, Advance Food Co. does not directly control management of process technology. |
Ammonia is self-alarming by its distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations (these concentrations would not result in any significant health risk). Most mechanical rooms with ammonia storage/process equipment , even well ventilated, may have concentr
ations around 5 PPM.
Ammonia is classified as a Group 2 Refrigerant per ASHRAE Standard 34-1992. The dominant characteristic of a Group 2 Refrigerant is its toxicity. Ammonia is self-alarming by its distinctive pungent odor. Due to this odor, personnel exposed to ammonia vapor will not voluntarily stay in areas of even small concentrations. Ammonia is readily absorbed into the moisture in the skin and, in heavy concentrations, can cause severe burns.
The Department of Transportation classifies ammonia as non-flammable. However, Ammonia is flammable within concentrations of 18 - 25% volume in air. Oil carried by the ammonia vapors in the process systems lowers this level considerably, and generally 4% by volume in air is considered the safe limit to prevent explosion.
In recognition of the potential adverse effects of ammonia release both from an employee and public safety perspective, Advance Food Company has instituted Process Safety Management plans at both of the aforementio
ned sites in addition to the existing safety programs. The plans include all phases of plant operation including conceptualization, design, construction, operation, maintenance, and decommissioning.
Both facilities' ammonia refrigeration systems are designed in accordance with the American National Standard for Equipment Design and Installation of Ammonia Mechanical Refrigeration Systems ANSI/IIAR-2-1992; the Electrical Safety Code for Mechanical Refrigeration ANSI/ASHRAE Standard 15; the IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System, IIAR Bulletin No. 109; the American National Standards Institute, "Safety Requirements for the Storage and Handling of Anhydrous Ammonia", ANSI K61.1-1989; the American Society of Heating, Refrigerating, and Air Conditioning Engineers, Inc., "Safety Code for Mechanical Refrigeration", ANSI/ASHRAE 15-1992, and the National Electric Code.
All employees involved with highly hazardous chemicals and processes, including operators, mai
ntenance personnel and contractor employees, require training to fully understand the safety and health hazards of the chemicals and processes they work with. Training under the HAZCOM Standard ( 1910.120 ) is used to familiarize affected employees with the chemicals and how to read MSDS's, however it is supplemented with training in such subjects as:
Standard Operating Procedures
Reading and using P & ID's in daily routine tasks and emergency conditions
Safe Work practices
Emergency evacuation and response
Work authorization activities
As with all safety training, documentation of employee's participation in the training are maintained on an individual basis.
Initial training is conducted for each employee currently involved in operating a process and for each employee before they are first assigned to operate a process. Refresher training will be conducted at a minimum of three-year interval unless changes in operations or process methodology prompt more
frequent training events.
Contractors performing work on the ammonia systems will be held to the same high standards as Advance employees and in conformance with the PSM standard. Specifically, Advance will assure the following:
The contract employers 'safety record is reviewed and evaluated.
The contractor employer is aware of the known hazards related to the contractor's assigned work and the processes.
The contractor employer is aware of all applicable provisions of the site's emergency action plan.
Procedures are in place to control the entry, presence, and exit of contractor personnel in process areas.
The contractor employer adheres to their obligations under the contract and applicable federal safety standards not limited to the following:
Contractor employees are trained in the safe work practices applicable to the assigned work.
Each contractor employee is instructed in known hazards and applicable provisions of the emergency action plan.
training and documentation is maintained.
Contractor employees adhere to safe work practices.
Advance Food Company representatives are apprised of any unique hazards presented by the contracted work.
The ammonia refrigeration system is critical to the production process operations, and therefore to the company's livelihood. As a result, preventative and responsive maintenance is a critical function. Those employees charged with the maintenance of these systems are knowledgeable and undergo continuous training to assure proper equipment function, process efficiencies and and as a result, the safety and security of the systems.
In recognition of the physical hazards associated with the use of anhydrous ammonia, written Hot Work and Confined Space Entry programs and associated training are utilized to cover welding or cutting on piping or components of a covered process, and/or entry into a designated permit required space. These programs incorporate requirements for othe
r non-routine work practices by individuals, including contractors, to include line break, lockout/tagout and temporary operational permits..
In order to properly manage process system changes, written procedures have been developed and implemented to coordinate these changes. This effort identifies and evaluates all changes as " change in kind " or majors, and produce documentation of the evaluation. The results of these evaluations may include procedural changes and require additional training before startup can be authorized.
Should the preventative actions addressed above be insufficient in preventing a system/component failure, the resulting incidents are treated as serious, regardless of the actual outcome. Advance Food does not measure the level of severity by the outcome, but instead on the recognized potential consequences. In order to effectively address this concern, a response program has been implemented to include the following:
All incidents and near misses are in
vestigated within 48 hours by a designated team.
The root cause ( s ) and factors contributing to the incident are defined.
Written corrective recommendations are provided to site management along with a plan to implement the recommendations of the incident investigation team. This report is shared with all affected employees and the documentation is retained for five years.
Should an event result in a loss of ammonia of significant volume, immediate evacuation of the affected areas is initiated in accordance with the site Emergency Action Plan. Depending on the circumstances, trained Advance employees utilizing appropriate levels of protective equipment may affect the required corrective actions. In any situation where this risk is deemed to be of unacceptable risk, outside response agencies (Enid Fire Department in Enid, OK and the Caryville Volunteer Fire Department in Caryville, TN) will respond. Current air dispersion modeling does not demonstrate significant risk to the public,
but appropriate notification and evacuation of potentially impacted areas will be initiated as appropriate to the situation.
As part of the company's continuos readiness program, local emergency response groups are toured through the facilities to assure a level of familiarity in terms of site layout, processes and procedures. Periodic drills both singularly and in cooperation with outside response agencies are periodically performed at both sites.
To assure that the programs addressed above are effective in terms of prevention and response, periodic audits will be conducted at a minimum of three-year intervals. Every five years these audits will be conducted by an external professional knowledgeable of the food industry, ammonia refrigeration processes and applicable codes and standards, including the OSHA Process Safety Management requirements.