Ammonia refrigeration systems that contain 10,000 lbs or more of anhydrous ammonia are required to comply with OSHA PSM and EPA/RMP requirements. These laws were enacted to prevent catastrophic releases and to protect workers, the public and the environment.

 The OSHA list of Highly Hazardous Chemicals, Toxics and Reactives defines the threshold quantity (TQ) for anhydrous ammonia as 10,000 lbs. However, this volume of ammonia is enough to fuel a "Catastrophic Event," so even with smaller quantities, responsible companies are complying with OSHA standards to improve the level of safety in their facilities. Ammonia can be dangerous at volumes much lower than 10,000 lbs so compliance with established standards is a win-win situation for workers and management.

"The employer must establish a system to address promptly the team's findings and recommendations; ensure that the recommendations are resolved in a timely manner and that the resolutions are documented...Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation." (OSHA 3132 PSM handbook)

All process hazard analyses must be updated and revalidated, based on their completion date, at least every five years. (OSHA 3132 PSM handbook).

After completing the initial process compliance audit, companies typically do follow-up inspections on a yearly basis, along with the mandatory 5-year inspection.

OSHA believes that "the process hazard analysis is best performed by a team with expertise in engineering and process operations, and that inspection and testing should follow recognized and generally accepted good engineering practices."
If your team has expertise with inspection and testing practices you are not obligated to contract third-party inspection services, however there is potential for oversight and internal bias that could skew results. Third-party Inspection Teams that benefit from performing numerous inspections in diverse facilities can offer a more complete and unbiased review of your system.

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