General Duty Clause (GDC)

Facilities that hold an ammonia charge less than 10,000 lbs are not subject to PSM and RMP compliance but are instead subject to both OSHA and EPA’s General Duty Clauses. 


IIAR has developed the Ammonia Refrigeration Management (ARM) Program to assist facilities subject to the GDC. This voluntary program was designed for facilities that operate relatively small ammonia systems to operate in a safe and responsible manner. 


Protexus provides the following services to our clients ARM program development:


  • Turnkey basis ARM programs - Each element of the program is tailored specifically to your facility;

  • Training of personnel responsible for managing the ARM Program.


The ARM Program contains 12 elements:


Management System


This element ensures the ARM  Program is developed and maintained by knowledgeable personnel so that the program can succeed. This element includes a list of personnel responsible for each individual ARM element. Also included within this element is employee access and participation in the ARM Program.


Refrigeration System Documentation


This element contains guidance on compiling the refrigeration system documentation. This information serves as a resource for conducting a hazard review for the facility. The refrigeration system documentation includes safety data sheet, ammonia inventory,  system operating ranges, Pressure Safety Relief Design and Design Basis, reference drawings such as block flow diagrams and P&IDs, Ventilation System Design and Design Basis, materials of construction, safety systems, Design Codes and Standards and Good Engineering Practices. Refrigeration System documentation should be accurate, and up to date to ensure an accurate assessment of hazards that may occur within the process during normal and upset conditions.


Hazard Review


This element provides guidance for facilities to identity, analyze, and evaluate potential hazards associated with the ammonia refrigeration system. The hazard review is used to assist employers in making decisions for improving safety and reducing the chances of a catastrophic ammonia release.


Operating Procedures (SOP)


The element is to ensure facilities develop, implement, and maintain clearly written, detailed procedures, guidelines, rules, and practices for the safe operation of the ammonia refrigeration system during all operating phases. 

Preventative Maintenance 


This element is to ensure the ammonia refrigeration system equipment is properly maintained. This includes the preventative maintenance, inspections and testing, non-destructive testing (NDT), and the third party 5 Year Mechanical Integrity inspection. Scheduled maintenance and inspection tasks are based on recognized and generally accepted good engineering practices such as IIAR's Inspection, Testing, and Maintenance of Closed-Circuit Ammonia Refrigeration Systems (ANSI/IIAR-6).




This element is to ensure all employees responsible for operating a covered process are trained, understand safety and health hazards, emergency operations and best work practices.


Compliance Audit


This element examines each element of the ARM Program and determines whether the associated procedures and practices are being followed.


Incident Investigation


The element is to provide guidance in investigating serious incidents and near-misses to understand what happened (or could have happened) and then to prevent any recurrence of similar incidents to improve the safety of the process.




This element is to ensure that contractors, subcontractors, and their employees are fully aware of the potential dangers involved with a process covered by OSHA and EPA’s General Duty Clause.


Emergency Response/Action Plan


This element is to provide guidance for addressing the actions which should be taken when there are emergencies at the facility such as ammonia releases. Facilities will need to decide what their actions will be for unwanted release, develop the necessary plans and procedures, and appropriately train and equip employees for their emergency duties and responsibilities.


Hazard Assessment


This element is to identify an alternative release scenario applicable to the facility and to develop a history of such releases.


Managing Change Program


This element provides the guidance to manage changes to the ammonia refrigeration system process, such as additions of new equipment or changes in operating, maintenance, or other procedures. A change includes modifications to process chemicals, equipment, procedures, technology or changes in a facility that affects the process.

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