IIAR Program Answers Industry with Small Facility Safety Guidelines
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 offsite 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?
Enter the Ammonia Refrigeration Management Program, a program built by the International Institute of Ammonia Refrigeration to help 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. Dean Foods’ Basel agreed, saying, “Our job has always been to operate a safe ammonia system. There are certain basic things that everyone in our industry must be aware of, but the rest of the safety process is often determined by what each plant decides to do depending on its workforce and size, and that’s where the process can get confusing.”
The ARM program is a streamlined version of the Institute’s PSM/RMP compliance guidelines, said Marrella.
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.
“With larger facilities, we’ve got more people and we’ve been following PSM since the 90’s. As an industry, we’re required to have operation and maintenance procedures written down and we have a more formal infrastructure run by employees with developed skill sets and specialists with a specific knowledge of PSM/RMP,” said Basel.
“That capability doesn’t necessarily apply to our small facilities, but we still need a way to do the same thing at the small facilities we operate in order to meet safety requirements. ARM allows you to formalize training and procedures and document what you have, how it works and how it should be maintained.”
Peter Jordan, senior principle engineer at MBD Risk Management and past IIAR Chair, said the genesis of IIAR’s ARM program came as OSHA and the industry as a whole turned its attention to safety practices at small facilities as process safety management became an industry standard at larger facilities.
“At the time, it was known that a number of larger companies were developing programs for their smaller facilities – to reflect the spirit of PSM/ RMP – but also to respond to the general duty clause. The idea was that the industry as a whole was looking for a way to apply these practices to smaller facilities,” said Jordan.
With ARM, IIAR formalized the effort to extend broader industry knowledge and safety practices to smaller companies and facilities.
“We basically took apart process safety management to look at what is absolutely necessary to have a safe system, and we tried to make that as simple and straightforward as we could. There are certain basics across the industry that ARM identifies, as well as suggested practices that may or may not apply to small facilities,” Jordan said.
The end result was a program that includes ten general elements that a facility operating with less than 10,000 pounds of ammonia should consider including in its program as well as specific guidelines contained in these elements that may or may not be appropriate for every facility given the wide range of operating conditions and acceptable safety management practices.
For smaller facilities, ARM is on its way to becoming a standard industry resource.
“Forty percent of my plants are following programs developed with ARM because they those plants are small operations,” said Basel. “And the reason is that I can’t impose a PSM program on a plant with two people in it. At small facilities, there’s simply not the skill sets or the manpower to get that done.”
Basel added that his company has used ARM as a way to outline basic practices and set up essential training for the number of small facilities it operates. “We are implementing ARM for small facilities at Dean Foods because we have so many of them. If you use ammonia, even if it is a small amount, you need to operate your plant safely. ARM says, ‘here’s what you need to do,’ even if you don’t have enough people to implement a PSM or handle the paperwork that goes with it.”
Long term, said Basel, the company hopes to institute ARM as a formal program that covers all of the company’s small facilities.
“We really think this program would be great for every smaller plant we operate, and it’s also a great tool for smaller, independent facilities without the resources of a large company behind them,” said Basel. “We’ve been very successful with the ARM plan in the plants where we’ve instituted it, and we’ve had a lot of success with the EPA as well.”
“ARM is an important program for everyone who operates small facilities in our industry, it makes us operate our systems smarter and it’s a really great starting point for smaller facilities and companies because it guides them through the process of maintaining their systems safely,” said Marrella. “ARM is really an essential tool for anyone running a facility with under 10,000 pounds of ammonia.”
