Today I got one of my favorite magazines, of which I have been suggesting everyone in the PSM arena subscribe to (for FREE) – The BULLETIN from the National Board. And in this edition, the NB has an article on the Hanson RV that has an indicator telling when the valve has been activated. These are a really nice addition to any process safety efforts, but in the NH3 refrigeration industry where almost all RV systems are manifolded together, they should almost be mandatory because of their ability to alert personnel when RV is lifted. But with these process improvements, come several changes to our process safety management systems and this calls for a MOC. Here are the potential impacts on our documentation that would suggest a MOC is in order to manage this change:
1) These indicators are in fact a visual alarm of a deviated process condition (most notably HIGH PRESSURE). These new alarms fit into our PSI under “Safety Systems” which will also kick in the PSSR requirement since our change is significant enough to require an update to the PSI.
2) The valves and their indicators come with some additional maintenance PM needs, meaning we should update our PM/Work Order, the maintenance procedure(s) for these inspections/tests, and the training on these revised inspection and testing procedures.
3) Since these indicators are essentially a process alarm, alerting personnel of a process deviation, we should update our SOPs to include this new safety system; as well as the steps we want personnel to take should they be notified of activation (steps to correct the deviation)
4) And with the SOP update to include this safety system in the SOP(s) and the specific steps to correct the deviation (Hi Pressure leading to a LOPC event) we will need to provide some formal training on this revised SOP(s) which will also need to have the means to verify knowledge of these new procedures. And I would do this for both operations and maintenance personnel and even engineering personnel.
So yes, these are a nice addition to have in an NH3 refrigeration process, but like any “change” their consideration, adoption, and implementation should be managed via a well managed MOC process, coupled with a thorough PSSR to verify all the PSI documents, operating and maintenance procedures have been updated and that the training needed has been completed and verified.