Speaking their language…

Posted on February 20, 2011 by Brian Chapin

I recently came across this fatality report from NIOSH about a workplace fatality which included this quote:

The foreign-born worker in this incident and a friend were hired together by a temporary agency to work as cleaners at the feed processing plant. The men were both native Spanish speakers. They received on-the-job training at the plant from their supervisor in English. Although the Spanish-speaking cleaner had very limited proficiency in English, he had lived and worked in the USA for 30 years, and was comfortable managing tasks in an English-speaking environment.

This is something a lot of us struggle with – we must train and supervise non-english speaking workers in a language they understand. One approach is to get a bilingual supervisor to work with you during Ammonia Awareness & Facility Evacuation trainings. In the past I’ve had flyers translated and distributed with paychecks – usually your bilingual coworkers are more than happy to help.

One word of caution though – You MUST ensure employees understand your training. It is not uncommon for workers to smile and nod through your presentation when they don’t understand any of it!

Here’s what OSHA has to say on the matter:

It is the Agency’s position that, regardless of the precise regulatory language, the terms “train” and “instruct,” as well as other synonyms, mean to present information in a manner that employees receiving it are capable of understanding. This follows from both the purpose of the standards — providing employees with information that will allow work to be performed in a safe and healthful manner that complies with OSHA requirements — and the basic definition that implies the information is presented in a manner the recipient is capable of understanding.

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The Failure of Lean/Six Sigma

Posted on January 20, 2011 by Brian Chapin

I’ve been asked in a few emails to comment on how to apply Lean/Six Sigma to ammonia refrigeration and PSM programs.

Short answer: Don’t.

The long answer follows but feel free to skip this once your eyes glaze over!

I gravitated out of Lean/Six Sigma work because I just don’t feel (as it is usually applied) it yields anything but pretty charts.

You see failed implementations everywhere you look and most businesses that attempt to utilize Lean/Six Sigma fail to see significant or lasting positive results. How bad is it really? How about up to a 98% failure rate for lean implementation? Would you take those odds on any other part of your business? When it works, it works gloriously – and that’s the results we get excited about and try to achieve. In a sense it’s the same reason people play the lottery.

It doesn’t have to be that way though. In my view we can remove the “chance” element from the equation if we remove the single reason most Lean/Six Sigma implementations fail: you can’t improve a process when you don’t have a reliable standard.They don’t fail because they aren’t exerting great effort, or because they are not using the tools properly – they fail because they are trying to use process improvement tools on a process that has not yet been standardized. You would be amazed at how many businesses can’t even explain their own process! W.E. Deming was on to something when he said “If you can’t explain what you are doing as a process, you don’t know what you are doing”

Almost everyone attempts to improve their process before they do the difficult work of standardizing that process. Imagine there is a short order cook trying to make scrambled eggs and you are asked by their supervisor to figure out how long to cook the eggs for optimum flavor.  Here’s what you’re likely to find:

  • The egg size was different every time – depends on what’s on sale that week.
  • The yolk to egg white ration is variable because sometimes the cook saves every other yolk for a sauce.
  • Sometimes they added milk, sometimes they added water, sometimes they don’t add either.
  • The salt shaker lid has different size holes on either side of the top so the amount of salt that comes out is variable depending on how you hold it.
  • The gas regulator is unreliable so the flame can randomly fluctuate between medium and high.

When that is the process you are using to make scrambled eggs you don’t get a lot of payback from focusing on how long you cook the eggs! There are too many variables outside of your control and until you control those variables you are going to have unreliable results. Furthermore, your end goal is “optimum flavor” – a subjective standard. Sure, you can turn “optimum flavor” into an objective standard but you can only do that by agreeing on a standard.

Sadly, this really is how most companies attempt to utilize lean and six sigma!

Please don’t misunderstand me – I think Kaizen, Lean and Six Sigma are great TOOLS to utilize on a standardized process. Think of Lean/Six Sigma as “finish work.” They are the polish you put on a newly painted car or the quality paint you put on your newly finished house. But if your house looks like the picture on the right, the quality of your paint is not the biggest problem you’ll be dealing with.

I would argue that painting that structure (applying Lean/Six Sigma) actually hurts the house because the money, time and effort you used for paint should have been utilized elsewhere.

Standardization is the first step on process excellence. It’s the most important step. It’s also the hardest step and that’s why it’s usually glossed over. Once you’ve standardized your process then you can use Kaizen and some other minimal Lean implementations to improve your process. No matter how hard you work at it though, if you skip standardization, you’ll never reap the rewards of any process improvement program.

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Dumping Ammonia Down the Drain? That’s a bad idea and it will cost you!

Posted on January 20, 2011 by Brian Chapin

“On Jan. 24, 2008, an ARC technician was performing a service job that required the removal of all ammonia from the refrigeration system’s 1,683-gallon holding tank, Assistant U.S. Attorney Bill Morse said. After transferring most but not all of the ammonia to other parts of the system, the technician drained the rest into a floor drain, which he knew led to a public treatment plant.

The amount of ammonia poured down the drain is disputed: Prosecutors estimate as much as 212 gallons, while the company contends it was as little as 15 gallons, Morse said. Regardless, upon arrival at the wastewater plant it killed much of the organic biomass used to treat the sewage, authorities said.” —Concord Monitor

These guys now face up to a $500,000 fine and up to five years probation! If you have to drain or purge ammonia out of a system put it into water where it can be diluted. You can then treat the water with Citric Acid or Vinegar to achieve a neutral PH. Or if it can be placed somewhere out of the way with controlled access you can let the ammonia vapor slowly dissipate out of the ammonia/water mixture over time. There are lots of good options to deal with it, but putting it down the drain is NOT one of those options!

Don’t dump it in a ditch or local stream either, or you’ll end up with something that looks like this:

This is what happens when you dump ammonia in a streamI assure you, the EPA will come calling if this happens. So will the media and probably an attorney or two. No good can come of that!

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Update your RMP at least Every 5 Years

Posted on January 20, 2011 by Brian Chapin

EPA requires you to update your RMP at least every five years. It doesn’t take long to do at all if you haven’t changed much in the last five years. You’ll almost always find a little thing to change, even if it’s just a better contact phone number.

Honestly, it takes less than an hour if nothing much has changed – it’s all done online and is fairly hassle-free. Don’t skip this easy step and end up like these fertilizer distributors did:

Two ammonia fertilizer distributors have agreed to pay over $33,000 for failing to update their plans for preventing chemical releases at eight facilities throughout Washington. One distributor will pay $13,521 and the other will pay $19,986 to settle alleged violations of the Risk Management provisions of section 112(r) of the federal Clean Air Act

Go to the EPA Website for more RMP information.

Update: Please see the comments for an excellent reminder by Peter Thomas.

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Kent Ammonia Leak an Attempted Theft?

Posted on January 13, 2011 by Brian Chapin

Usually the meth-makers pick on agricultural ammonia sources but they occasionally go to a cold storage as well:

“The attempted theft of ammonia appears to be the cause of a leak Tuesday morning at the Washington Cold Storage facility in Kent…” —Kent Reporter

I’m hearing that this was from a charging (sometimes called a fill) line outside the engine room. If that’s the case then there is a lesson to be learned here. One good option is to pipe your charging line like this:

You keep the valves on the left closed unless your actually adding charge to the system. The valves on the right are outside the building and although they could be opened by would-be thieves, they wouldn’t get anything for their efforts. The pressure indicators in between the closed valves are to ensure you aren’t leaking liquid into the the space between the valves and to give you a convenient location to purge from if needed.

I’ve also seen people encasing these outside valves in a locked metal cabinet which is not a bad idea at all. How do you protect your fill valves from troublemakers?

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Everything is working just fine – Now is the time to improve!

Posted on January 12, 2011 by Brian Chapin

Ever get down because the operator that is always “fixing” a “broken” refrigeration system is viewed as a hero while the operator who reliably and efficiently operates a system is forgotten about? Read on and see what I think you can do to get back on your boss’s radar even when things are running smoothly!

“Don’t fix what isn’t broke” is a good maintenance motto for much of your refrigeration equipment but it is a lousy motto for processes. Sometimes a piece of machinery is just perfectly suited to the task you are asking it to do. Let’s use one of my favorite examples: the M1911 pistol:

The design is essentially unchanged since its introduction in 1911. That’s some awe-inspiring design! Firearm manufacture started in the 13th century and through constant improvement became what we now take to the pistol range. Imagine if those early inventors worked on their new machine and stopped the minute they got something that “got the job done” without trying to make it work better:

I’m not suggesting you start tinkering with your ammonia pumps and compressors; Modern refrigeration equipment is extremely complex and finely tuned. Chances are though, that you do have plenty of suboptimal processes using that equipment. For many end-users, if the cold area is cold then things are “working” and they want things left alone. The fact that they may be overstressing their equipment and wasting tens of thousands of dollars in extra electricity is not known or simply ignored.

Let’s say you are one of the great refrigeration operators out there: you’re professional, attentive, and knowledgeable. You adhere to your mechanical integrity schedule for preventative and predictive maintenance with an almost religious zeal. Because you do the right things your system operates with very little downtime. The result of all this work, if you are like the vast majority of great operators out there, is that you fall off your boss’s radar. They don’t think about you because they don’t have to worry about refrigeration working for them. Your success means you shrink into the shadows – never a good place to be if you are looking for a promotion or a pay raise!

Is there a way out of this situation without creating “opportunities” to come to the rescue? Yes, there is! You already operate your system in a standard manner that works well, but is there a way it could work better? What would better look like? Would lower electrical costs, reduced downtime and minimal wear & tear be better? If you could quantify those positive changes in dollars, wouldn’t that get you back on the radar at work?

You bet it would! Very few things speak to management louder than dollar bills!

Average Head Pressure:

Results on a 16,000# -40F NH3 System

Electricity Usage:

Don’t settle for “good enough” when you have room for significant improvement. Excellence isn’t just a skill – it’s an attitude too. Optimize your defrost schedules, properly set your back-pressure regulators, balance your evaporators, de-scale you condensers, monitor your chemical concentrations to reduce usage, lower your head pressure. There are almost always things you can improve! Document your improvements and the savings from them and present them to your management. With any luck you can get the well-deserved positive attention you need for that long sought promotion and raise!

Posted in General Information, Standardization, System Optimization | Tagged , | 1 Comment

Garden City Ammonia Program PodCast

Posted on January 12, 2011 by Brian Chapin

I recently had a long conversation with Craig Ward of Garden City Ammonia Program. He turned it into an episode for their GCAP Cool Cast. You can listen to the entire conversation here.

As always – feedback is welcome.

Posted in Community Involvement, Compliance, General Information, Good Engineering Practices, Operator Training, Standardization | Tagged , , , , , , , , , , | Comments Off on Garden City Ammonia Program PodCast

SOP Development Tip – Leave the Multitasking to the Computers

Posted on January 9, 2011 by Brian Chapin

As any parent can attest, it’s possible (though hardly optimal) to do two things at once – as long as none of the tasks you are performing require much thought. You’ve probably noticed that when you multi-task it’s very easy to commit errors. Some studies have found that drivers who talked on their cell phone were more likely to crash than those who were intoxicated.

There is a reason for this – Our brains prefer to swap between the two tasks to think about them separately. Because of this trying to do two things at once is rarely as effective as doing them one after another. Here’s a quick experiment you can perform to see what I am talking about:

Time yourself doing the following activities.

1) Print your full name while spelling “Ammonia Refrigeration” out loud at the same time.

2) Print your full name then spell “Ammonia Refrigeration” out loud.

I get about 15 seconds doing it the first way and about 6 seconds doing it the second way. It’s not hard to walk and chew gum at the same time because neither one of them take much mental bandwidth. Ever try and perform arithmetic while carrying on a conversation? It does NOT work out well for most people! So, why does any of this matter? What we try to do with a properly written SOP is to standardize the process so the operator can freely think if something out of the ordinary happens.

Bill Marriott perhaps said it best: “Standard processes and methods are NOT about creating mindless conformity. Standard methods are all about eliminating the constant hum of the hundreds of decisions that would take place all day so you can have the mental bandwidth left to focus on the few major problems that pop up.”

There is a danger however in standard processes that following them routinely over and over again tends to put your brain in idle while performing the task. Here’s one tip I use to try and keep the operator thinking while performing a standard task. Look at the following step from an operating procedure below:

1) Fully close HV 13-01.

Pretty bland right? I train operators to read the complete step before they perform it. Many times I’ll include explanatory text in italics as well. Let’s dress that step up to inform the operator and keep them engaged in the procedure they are performing it:

1) Fully close the Liquid Isolation Valve (HV 13-01). Performing this step stops the flow of liquid to the air unit by isolating it from the HPL line. Note: Closing this valve will temporarily trap a small amount of liquid between the Liquid Isolation Valve and the Liquid Solenoid Valve (LSV 13-02) so proceed immediately to the next step!

That works out much better for nearly all the operators I’ve worked with. The operator is engaged directly in the procedure and thinking about the ramifications of the step they are performing – the actual valve closing doesn’t take much mental bandwidth.

So here are my two tips for you on SOP development and Multi-tasking:

1) Where possible, always write your SOP steps so they avoid concurrent tasks and perform tasks in series.

2) Write your steps so they keep the person performing them engaged in the task and the procedure itself.

If you have any thoughts, I’d love to hear them in the comments or through email.

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Updated Links

Posted on January 8, 2011 by Brian Chapin

I’ve added a bunch of links concerning ammonia refrigeration and process safety management to the right hand side of the page. A few  contractors, a lot of manufacturers and vendors as well as some other useful sites.

If you know of any that I have missed feel free to email them to me at [email protected]

Update: placed all the links on their own page with some comments.

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RAGAGEP: Just what is it?

Posted on December 26, 2010 by Brian Chapin

RAGAGEP stands for Recognized and Generally Accepted Good Engineering Practice.

OSHA: OSHA 29 CFR 1910.119 (D)(3)(ii): “The employer shall document that equipment complies with recognized and generally accepted good engineering practices.”

EPA: EPA 40 CFR 68.73 (d)(2): “Inspection and testing procedures shall follow recognized and generally accepted good engineering practices”

Simply put RAGAGEP is just the standards and practices that the majority of the industry follow. For ammonia refrigeration you generally refer to the ANSI/IIAR standards. OSHA dealt with the question of RAGAGEP (specifically about whether you need to update equipment to meet new standards) in a 2006 interpretation:

Question 9: Which ANSI/IIAR standard will OSHA deem to be applicable to a system built prior to 1999?

Response 9: If an employer was in compliance with PSM for a process built before 1999, then it will have PSI which shows the design codes and standards employed for the equipment in its covered process, 29 CFR §1910.119(d)(3)(i)(F). Additionally, all equipment in the covered process was designed, fabricated, installed, operated, inspected/tested/maintained, and changed per some RAGAGEP. To manage and ensure this, employers have documented per 1910.119(d)(3)(ii) that the equipment complies with RAGAGEP. This documentation established the “fitness-for-duty” for the equipment and became the baseline for all future operation, inspection/testing/maintenance, and change. Once this baseline has been established and the employer follows all PSM requirements including all applicable RAGAGEP, OSHA generally does not require the employer to upgrade its covered equipment to meet a change in a latter version of some RAGAGEP. The only exception to this would be if the equipment was being changed and an applicable RAGAGEP required that the equipment be updated to meet the latest version of the RAGAGEP. It is important that employers identify and document RAGAGEP for covered equipment, as that is the basis for managing the safety of the equipment over its lifetime.

Therefore, if the employer documented that it used ANSI/IIAR 2 — 1992 as one of the codes and standards it employed [per 1910.119(d)(3)(i)(F)] for some aspect of a covered process which was started-up in 1994, and if the employer documented that the covered process met the RAGAGEP requirements of 1910.119(d)(3)(ii), OSHA would not require the employer to comply with the requirements of ANSI/IIAR 2 — 1999. This assumes the employer has followed all PSM requirements and there are no equipment updates or changes required by ANSI/IIAR 2 — 1999 or some other latest version of an applicable RAGAGEP.

So the short version is: You define the design criteria (code, IIAR, etc.) and then you will be held to it.

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