Keeping Regulators at 'ARMs' Length
As many of you know, ammonia refrigeration facilities with a charge of greater than 10,000 lb of ammonia are required to comply with the Occupational Safety and Health Administration's process safety management (PSM) standard, 29 CFR 1910.119, and EPA's risk management program (RMP), 40 CFR Part 68. Smaller facilities in most of the United States must comply with the General Duty Clause, which is Section 112 (r) (1) of the Clean Air Act.
Designed to prevent accidental ammonia releases, PSM was well intentioned. A common complaint, however, is that OSHA and EPA used an approach that does not apply specifically to the ammonia refrigeration industry. The result is that these regulations include areas that may cause problems or reduce productivity for those who work in ammonia refrigeration facilities. The problems are magnified at smaller facilities. IIAR published guidelines to help companies comply with PSM and RMP, and they have been very useful. That kind of guidance has been lacking for compliance with the General Duty Clause. So, before the federal government shoehorns smaller ammonia refrigeration facilities into another one-size-fits-all approach to chemical safety like PSM, IIAR developed the Ammonia Refrigeration Management (ARM) program. The ARM program contains voluntary industry guidelines to help companies comply with the General Duty Clause and develop a management system that also will help to ensure facilities operate safely and efficiently.
The program will assist management to identify special hazards, ensure that codes and standards are followed, and provide a contingency plan for emergency response. It has ten elements:
Management System -- identifies the overall program manager and the managers of the various program sections. Operators would have a part in the development and involvement in all areas of the program.
Refrigeration System Documentation -- includes items such as material safety data sheets, ammonia inventory, piping and instrumentation diagrams, a plant plan, equipment list, system operating parameters, safety systems and ventilation systems descriptions, O and M manuals, and pressure vessel data reports.
Operating Procedures -- includes written startup and shutdown procedures and procedures for daily logs and lock out/tag out details.
Preventive Maintenance Program -- covers all refrigeration equipment, including proper documentation, and ensures the equipment is maintained according to manufacturer's recommendations and good engineering practices.
Contractor Program -- ensures refrigeration contractors are qualified and trained in ammonia refrigeration.
Emergency Response Program -- developed to cover plant personnel and others who may respond to ammonia releases.
Incident Investigation Procedures -- developed to ensure that any incident is properly recorded and analyzed.
Training Program -- calls for ongoing operator training.
Hazard Review Procedures -- includes procedures to identify and analyze potential hazards in the refrigeration system and address recommendations for review.
Refrigeration Stem Change Program -- outlines procedures to ensure that modifications to the ammonia refrigeration system are noted.
Those of you familiar with PSM may be thinking this looks awfully familiar. In one sense it does -- it was patterned after PSM. But here's the difference: Generally speaking, ARM is not a paperwork-intensive program. Most of these elements will require only two or three pages of documentation, though additional paperwork will be required for some. Operators and their supervisors can concentrate more on system maintenance and operator training instead of paperwork. The way I see it, it's a more cost-effective way of achieving the goals of PSM while using a program developed specifically designed for ammonia refrigeration.
This new program is in the final stages of development and is being tested in an actual facility. EPA and OSHA will be given an opportunity to look it over, and it will get a full legal review. Obviously, this is a work in progress. You'll have your chance to offer ideas in March at the IIAR Conference and Exhibition in Albuquerque. A paper will be presented to give an overview of the program, and a forum has been scheduled to get feedback.
Over the years, I've developed quite a few PSM programs in cooperation with ammonia refrigeration plant operators. My main concern was the amount of time and the volume of paperwork necessary to satisfy the OSHA requirements. Based on the sneak peek I have had of this new IIAR program, it requires significantly less documentation and paperwork to demonstrate that the plant is operating safely (and efficiently). Who knows? If the program works well for those companies covered by the General Duty Clause, maybe we can convince the OSHA to think about using it for all facilities.