Process Safety Management (PSM) and Commercial Refrigeration

I was watching reruns of the "The West Wing", and I was noticing that the positions which the Administration in the series were taking would not be the positions taken at the present time. I'm using this comparison to make a point that the regulatory environment for refineries, chemical plants, and other industries linked by the OSHA Highly Hazardous chemicals list is not what it used to be. What was once acceptable no longer is. It used to be in the old days that OSHA would not come in and audit you unless you had a fatality in your facility. Those days are long gone and what started out as the result of refinery explosion has morphed into a proactive engagement in making sure companies are complying with Process Safety Management (PSM). Many of us know but for those who don't, the program is called the National Emphasis Program or NEP. OSHA and the EPA are now proactively auditing facilities. This is not a bad thing since process safety management has been shown to pay serious dividends.

It began with refineries, moved on to chemical plants, and now the latest guidance states that the NEP targeting list will have revision of priorities. We are told the first targets for their priority list will be the largest offenders from the OSHA and EPA violations databases. In addition their targets will come from four broad categories which are:

• Category 1 - Facilities with NAICS codes likely to have ammonia used for refrigeration as the only HHC
• Category 2 - NAICS 32411 or 324110, Petroleum refineries
• Category 3 - NAICS 325, Chemical Manufacturing
• Category 4 - NAICS codes for facilities that are likely PSM covered but not category 1, Category 2, or Category 3

While it makes sense that the worst offenders would go on the target list first, many industries other than chemical processing or refineries use anhydrous ammonia as a very efficient commercial refrigerant but it is also highly toxic. Anyone who has been following the U.S. Chemical Safety and Hazard Investigation Board (CSB) has seen the number of anhydrous ammonia releases at commercial refrigeration facilities in the news feed. Also anyone familiar with CFR 1910.119, Process Safety Management, knows that anhydrous ammonia is on its list for highly hazardous chemicals with a threshold quantity of 10,000 lbs. For those who don't know, if you have anhydrous ammonia at your facility in an amount greater than or equal to this threshold quantity, you might need to make sure you are in compliance with the OSHA regulation prior to your potential NEP audit. An AOC consultant can provide you with more information about this or help you determine whether your facility needs to be compliance with PSM.

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