Developing Guidelines for Smaller Facilities
While larger facilities – those that use less than 10,000 pounds of ammonia – have long been subject to formal federal safety requirements, the question of how to develop guidelines that work just as well for smaller systems, those under 10,000 pounds, has often been a murky issue.
The consequences of an operation related incident are not murky. When it comes to safety, prevention is the most important factor in avoiding those potential consequences. Whether a facility is working with 900 pounds or 90,000 pounds of ammonia, the risks of an incident are similar. The severity of a potential problem could be less with a smaller facility, but the risk is still there.
As the industry sees a greater prevalence of smaller systems put on the market to replace synthetic refrigerants, as well as increasing OSHA awareness of the potential hazards of those systems, industry safety practices go a long way in protecting the reputation of smaller facilities.
For example, a smaller facility may not see the level of off-site consequences an incident at a larger facility would see, but it would certainly face on-site consequences, an outcome no company can afford, especially when such an incident could prompt local news media coverage.
Given those challenges, how should a small ammonia refrigeration facility determine the practices that are the most efficient for its own operations in the face of so much conflicting and often redundant information about safety practices that may or may not actually apply to smaller operations?
The Ammonia Refrigeration Management Program, a program built by the International Institute of Ammonia Refrigeration, helps small facilities answer that question by helping them develop a good safety plan focused on prevention.
Traditionally, larger ammonia refrigeration facilities – with charges greater than 10,000 pounds – have been required to comply with OSHA’s Process Safety Management Program and EPA’s Risk Management Program requirements. In part because of those regulations, in place since the 1990s, the most common misconception among smaller facilities has been that they are exempt from compliance issues because the size of their charge is less than 10,000 pounds. Nothing could be further from the truth, said Larry Basel, past president of IIAR and Director of Environmental Health and Safety for the East Region at Dean Foods.
“Sometimes it’s hard to determine what all those safety factors are and how they should be applied unless they are laid out according to the institutional knowledge of the industry, and that’s where the Ammonia Refrigeration Management Program is an incredibly valuable tool,” said Basel.
In addition to the safety and public relations considerations, there is a regulatory compliance issue for smaller facilities. The general duty clauses of OSHA and the EPA, cover every refrigeration facility, including those with less than 10,000 pounds of ammonia. These regulations can be found in 29 USC 654(a)(1) (OSHA) and the Clean Air Act Section 112(r) (1) (EPA). They set a minimum safety standard and place responsibility on employers to keep workers and neighbors safe from hazardous chemicals.
The IIAR’s ARM program is one tool any small facility can use to meet the challenges posed by a regulatory environment – an environment that often delivers non-prescriptive specifications for safety. Drawing on the cumulative experience of the industry, ARM helps companies and facilities identify the specific safety practices they should pursue, answering the common question: What basic safety processes should small ammonia refrigeration facilities observe and how should they build a safety program that is suited to their unique operations?
While safe and efficient operation has always been a driving force behind the innovations of the industry, even larger companies with multiple small facilities are turning their attention to safety programs as they increasingly expand their operations beyond a central, large facility, to facilities with less than 10,000 pounds of ammonia.
As the industry continually evolves to meet the demands of a complex regulatory environment and fast-paced supply chain, the need to develop and implement ARM programs at small facilities is indeed a challenge faced by everyone in the industry, said Jim Marrella, Co-chair of the IIAR ARM task force and Coordinator of OSHA and EPA Compliance and Training for United States Cold Storage.
“The operation of a safe and efficient system is our primary goal, but over the years the definition of what exactly that means has evolved through the work of IIAR and its members as well as members of the regulatory community,” said Marrella.
The ARM program is a streamlined version of the Institute’s PSM/RMP compliance guidelines, he added.
The ARM Program addresses topics such as the management system, documentation, contractors, mechanical integrity, and emergency response, and simplifies the record keeping and program maintenance elements of the more complex PSM and RMP requirements.
