MORE THAN 10,000 LBS AMMONIA

PSM/RMP Elements

Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years at or above the threshold quality defined by OSHA. Anhydrous ammonia threshold quantity is 10,000 pounds.

 

Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled, creating the possibility of disaster.

 

To help ensure safe and healthful workplaces, OSHA issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes using highly hazardous chemicals. According to OSHA, Process Safety Management (PSM) refers to a set of connected management approaches intended to reduce the frequency and severity of incidents resulting from chemical releases. PSM programs have many moving parts: process safety leadership, risk identification, assessment and management, and continuous reviews and improvement plans.

In order to maintain and sustain effective PSM Programs, you must have proper procedures in place. We know that governmental auditors are looking at a company’s PSM Programs to ensure they are effective in reducing the frequency and severity of an incident as exemplified by the company’s implementation of the programs.

 

Additional documentation that PSM facilities are required to be submitted to OSHA and EPA are the Risk Management Plan (RMP) and Tier II report.

Protexus provides the following services to our clients for PSM program development:

 

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

  • Review of existing PSM elements to ensure alignment of documentation and implementation

  • Training of personnel responsible for managing the PSM Program

  • RMP Submission

  • Tier 2 Submission 

The elements of PSM/RMP programs include:

Management System

This element is to develop and document a management system to oversee the implementation of the Risk Management Program elements.

Employee Participation

 

This element is to provide for a cooperative, participatory work environment and a flow of information between employees and the management concerning process safety. The program will address how employees will participate in the development of the PSM program and the evidence of the participation (PHA participation, SOP development, meeting minutes, etc.). 

 

Process Safety Information

 

This element contains the information about the refrigeration process. This information must be gathered before a Process Hazard Analysis can be completed. The process safety information must include chemical data, process technology such as maximum ammonia inventory levels and operating limits, Pressure Safety Relief Design and Design Basis, reference drawings such as block flow diagrams and P&IDs, Ventilation System Design and Design Basis, and process equipment design and maintenance materials. Process safety information must be accurate, and up to date to ensure an accurate assessment of normal and upset conditions when conducting the Process Hazard Analysis (PHA).

 

Process Hazard Analysis (PHA)


This element is to ensure a study of the ammonia refrigeration system is performed to identity and analyze the significance of potential hazards associated with the process and to provide information to assist employers in making decisions for improving safety and reducing the chances of a catastrophic release.

Operating Procedures (SOP)

 

This 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.

 

Training

 

This element is to provide guidance on preparing a training program for those who operate, maintain, or supervise the operation of the ammonia refrigeration system.

 

Contractors

 

This element is to ensure that contractors, subcontractors, and their employees are fully aware of the potential dangers involved with a process covered by PSM and RMP.

 

Pre-Startup Safety Review

 

This element is to ensure that adequate safety measures are in place and operational BEFORE ammonia is added to the system. A PSSR is usually completed in conjunction with the Management of Change Program.

Mechanical Integrity 

 

This element is to ensure the ammonia refrigeration system equipment is properly maintained. This includes the preventative maintenance, annual inspections and testing, non-destructive testing (NDT), and the third party 5 Year Mechanical Integrity inspection.

 

Hot Work

 

This element is to ensure that all affected employees, contractors, visitors, company property, and the community surrounding the facility are properly protected against fire, explosion and other dangers resulting from hot work (work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations) performed in or around the covered process.

Management of Change

 

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. 

 

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.

 

Emergency Planning and Response

 

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. 

 

Compliance Audit

 

This element examines each element of the PSM and RMP programs and determines whether the associated procedures and practices are being followed. Compliance Audits are required every 3 years. 

 

Trade Secrets

 

This element is to document the procedures which ensure that employees are provided with information while still protecting company secrets. This usually does not apply to ammonia refrigeration systems. 

 

Hazard Assessment

 

This element is to identify and analyze worst-case and alternate case release scenarios applicable to the facility and to document the five year accident history of such release. The Hazard Assessment is developed as required for the RMP submission.

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