We would like to take this opportunity to introduce to you what we feel is probably one of the most important systems that we have ever developed for the New Zealand Ammonia industry.
We all know that we are dealing with a hazardous material when we consider the ammonia in the refrigeration plant and most likely you feel that with the training your technical staff have received, they will cope with whatever comes their way.
Hopefully, they will…
The likelihood that they will be able to manage an incident effectively is low simply due to the lack of practice in Ammonia emergency management and that a broad scope Emergency Response document does not provide enough vital information nor the resources to deal with an incident properly. It is not a capability!
It is after all just pieces of paper…
What exactly is an Emergency? – An emergency is an unexpected event which threatens or has affected, people’s Health, Safety or working condition of property & assets.
An Emergency Response Plan is, therefore; the necessary actions to respond immediately, effectively and safely to any unexpected event which threatens life.
An emergency capability is the access to the appropriate resources and the overall competence in executing the plan.
Wearing PPE and completing JSA and Permit to works has become a somewhat ritualistic practice for many years now and it is now something that needs little reinforcement.
Needless to say, we very seldom get to practice Emergencies and generally when there is time allocated, they are simply evacuations with no credible complexity of a real-life situation. How are we meant to be competent in something without practice?
It’s likened to reading an article (not a book) about martial arts then stepping into the ring with Anderson Silva. You are gonna get your ass kicked!
This lack of emergency practice is likely down to maintaining the day to day business operations and delivering high product yields, after all, bills must be paid and money is to be made.
But what happens when you lose business continuity due to evacuating the entire site for a localised – low consequence emergency or worse still, what if it is a full-scale major consequence emergency?
How long will your business be out of operation due to a poor response effort – how much product will you lose?
What happens when people are missing or injured?
The power is lost at night – it is cold and raining?
Your windsocks are not visible?
Communication is compromised or difficult?
But that is why we just call the fire service, they will fix it, right?
Firstly, Fire and Emergency personnel may not be able to reach your site due to the wind direction and in rural areas, you will have to wait for the Hazmat Response Unit to arrive before any actions are taken to identify, contain and control the incident.
You may be left to manage the incident alone and communicate with off-site responders.
It’s all about situational awareness and your capacity to communicate the event whether they are on available to attend site or not.
“Co-ordination is achieved via the CIMS based Emergency Plan, ensuring a focused rapid initial response and ongoing seamless interface with external services on arrival”.
It should also be appreciated that the emergency services do not necessarily understand the issues with Ammonia releases, you must prepare for this eventuality in house, after all, you know your site better than anyone.
In no way do I mean to discredit the capability of the New Zealand Fire Service but their duty is to protect and save lives and property, they do not know how to resolve engineering problems – particularly complex Anhydrous Ammonia Refrigeration systems.
According to Fire and Emergency, the New Zealand Ammonia industry which has approximately 200 facilities has on average 20 -30 accidents per year and according to Accident Compensation Corporation results in 14-20 claims per year. Worksafe Official Information depicts less than half these numbers meaning that the leaks are not all being reported through various channels. This aside with numbers this high, It is only a matter of time before a fatality occurs.
Obviously, prevention is the best foot forward, good design and asset management are essential, yet the possibility of an uncontrolled release remains a possibility that must be prepared for.
There are many plants in the Oceanic region that fail to even meet the retrospective standards from the 1930s let alone the major-league standards of today.
Over the years we have reviewed countless Emergency Response/Management documents and all, but a small handful have been below the regulated level of compliance or have defied logic completely
There are several similarities in the plans that we observe and attempt to correct which include one or more of the following:
- Call 111 – that is pretty much it.
- A single page in a broad scope Emergency Management document with little detail of what actions to take and when to take them.
- The wording “in an emergency” – what is an emergency? What are the thresholds?
- A list of workers and their contact numbers – without mention of their specific duties in an emergency.
- A list of names without contact numbers… “Call Dave”
- No contingencies or proxy roles when those above personnel are out of reach (the ones with contact numbers)
- No specialist contractors mentioned in the plan.
- No crisis management or business continuity plan activation.
- Directions to evacuate to an assembly area right in the path of the predominant wind direction.
- No first aid information explicit to Anhydrous Ammonia.
- No readily available maps, Plume models or Plant drawings
- No shelter in place (SIP) strategies adopted.
- Advice to Shut “king valve” – Will this be beneficial at all or will it do nothing and put people in danger?
For this very reason, we collaborated with Mines Rescue Trust New Zealand and developed a simplistic framework that provides easy to follow Rapid Reference Tools and Duty cards to deliver a Safe, Effective, Rapid and Proven response effort.
The system is our Ammonia Specific Emergency Management Plan using TARP™ principles.
Triggered Action Response Planning slots seamlessly under your existing emergency management plan, it is an incident-specific response tool that allows you to make risk-based decisions & provide optimum situational awareness for all stakeholders involved in your emergency.
The Co-ordination is achieved via the CIMS based Emergency Plan, ensuring a focused rapid initial response and ongoing seamless interface with external services on arrival.
“Having better situational awareness, – I’m all for it”. – David Woon
To ensure our system was suitable for deployment we held an industry advisory group session in December 2017 with Key Emergency Services personnel which included, Fire and Emergency Regional Commanders, St Johns Emergency, Civil Defence, the New Zealand Police Force USARS, Mines Rescue and the Chemical Association (Responsible Care). Modifications were made to some structures under the advice of the participants however it was well received.
“I really like the simplicity of the resources”. -Dr Trudy Geoghegan
Whilst it is a legal requirement that all pressurised systems operating at a pressure above 50 kPa must conform to the Pressure Equipment Regulations you are also required under the Hazardous Substances Regulations to have an Emergency Plan and to undertake at least yearly a site exercise.
For anyone who has ever been involved in a full-scale emergency, they will know how quickly things go “pear-shaped” when there is no plan, or the plan is below standard.
Sure, the refrigeration technicians are experienced and qualified to maintain and service the plant –
But the reality is that attending to a full-scale major incident is a once to twice in a career job for most Ammonia Refrigeration technicians.