IIAR Releases New, Updated PSM/RMP Program Guidelines
“The updated guidelines will prove useful for any company interested in practically applying management procedures that lead to a comprehensive safety plan,” said Bruce Badger, IIAR president. “Such a safety plan directly responds to PSM and RMP rules and regulations and is the first step in establishing and maintaining a safe ammonia refrigeration facility.”
“IIAR would like to recognize all the volunteers who gave their hard work and attention to this project,” said Badger, adding that the seven-person committee included chairman Jim Marrella, principal writer Peter Jordan, and members Gary Webster, Kem Russell, Godan Nambudiripad, Ron Worley and Martin Timm.
“These new guidelines reflect ten to 15 years of experience in implementing what OSHA and EPA originally meant to accomplish with their two separate regulations,” said Jim Marrella, Cordinator of OSHA and EPA compliance for United States Cold Storage, and chair of IIAR’s PSM/ RMP Task Force. “This reflects the entirety of our real-world experience as an industry. IIAR has brought together the very best and most experienced professionals, to form a committee made up of PSM/RMP experts. As the result of some very hard work by this committee, we now have a much greater understanding of how these regulatory agencies will apply this law in practice.”
Marrella said the main goal behind IIAR’s work on the PSM/ RMP guidelines was the feeling that the program should be brought up to date to reflect industry experience with the regulations as well as a more robust and communicative relationship between the industry and federal regulators.
“The main reason we did this update was because we wanted to include the latest information, the appearance is still similar, but the substance has changed quite a bit because we have years of experience now,” he said. “We really tried to find a middle ground where everyone could use the program…from the expert down to the novice. It’s not generally an easy program to apply to facilities; this committee really worked hard to make IIAR’s guidelines user friendly and relevant to everyone.”
Two important changes mark IIAR’s most recent release of the guidelines. The first change, the combination of previously separate PSM and RMP guides, will serve to provide a much more integrated framework for companies looking to take a holistic approach to creating a safe and efficient operation that is compliant with OSHA and EPA regulations.
“These regulations really should have been combined from beginning, but because all regulatory agencies are departmentalized, that didn’t happen in practice,” said Don Siller, past IIAR chair and honorary life member. “Now that we have experience with this process, we can look at these regulations, both as an industry – and for EPA and OSHA as federal regulators – and integrate all the functional and managerial elements that are at the core of both guidelines.”
The second important change reflected in IIAR’s update includes a much more dynamic approach to helping industrial refrigeration companies develop their own customized PSM/ RMP program with attention to the specific ways the regulations apply to their own operations.
“The PSM/ RMP programs in an ammonia facility cannot, and never were intended to be books sitting on shelves,” said Siller, who was the co-chair of the first committee tasked with producing PSM/ RMP guidelines. “While the original guidelines were invaluable in beginning the process of meeting these regulations, the IIAR updated guidelines help companies create a much more dynamic program. Regulators have now begun emphasizing the importance of active participation in these safety programs as opposed to having files full of documentation, and the new guidelines help companies create that active participation.”
The new guidelines, titled, Process Safety Management and Risk Management Program Guidelines, was written under the premise that many users will choose to consolidate their PSM and RMP elements into one, inclusive program. Different options have been chosen by other users which are equally effective. Some users have chosen to separate their PSM and RMP elements into two distinct programs. Either option is perfectly acceptable provided that all PSM and RMP program requirements are addressed.
Additionally, a desire to maintain safe and efficient operation of industrial refrigeration systems is paramount on the minds of any individual who handles ammonia on a day-today basis.
“These new guidelines really reflect the experience of all the employees who deal every day with the separate processes addressed by the OSHA and EPA regulations,” said Marrella. “It is a performance standard rather than a specification standard, so that means it depends on everyone’s participation.”
IIAR’s new guidelines address the employee’s role in meeting PSM/ RMP regulations, giving them an opportunity to take part in a facility’s program, he said.
“That’s important because these are the people who work with the program every day. They apply OSHA and EPA standards every day, and now, if a company chooses to update their original program or create a new program using IIAR’s guidelines, those people will have much more guidance in their day-to-day operations.”
“It really comes down to the efforts of our members and all the people involved in making our industry safer,” said Marrella, a process that began in the 1990’s.
Ultimately, the Clean Air Act (CAA), as amended in 1990, required the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) to address concerns that chemical accidents could pose a risk to employees, the public, and the environment, setting the stage for the PSM and RMP regulations that followed.
Emphasis was placed on the proper management of hazards associated with ammonia to help assure safety through creating internal management programs in facilities directly dealing with hazardous chemicals.
EPA’s Risk Management Program (RMP) rule, which took effect June 21, 1999, is focused on the protection of the public and the environment, while OSHA’s Process Safety Management standard, which took effect May 26, 1992, is focused on the protection of employees and on-site contractors. Although often seen as separate, the shared objective of these two programs is to prevent accidental chemical releases and minimize their impact if they do occur.
In response to the direct effect both regulations have had on ammonia refrigeration facility management, IIAR’s original Process Safety Management Guidelines, published in 1994, were meant to function as a guide for companies to understand and interpret OSHA’s PSM standard. The manual was then updated in 1998 to include lessons learned from the first five years of PSM implementation and enforcement and a companion manual entitled Risk Management Program Guideline, to address the EPA’s RMP rule, was also published in the same year.
IIAR’s new Process Safety Management and Risk Management Program Guidelines, comes replete with the benefit of experience from many industry leaders who have developed both consolidated and individual management and safety programs successfully.
Each chapter in the Process Safety Management and Risk Management Program Guidelines is divided into two parts. The first section is a grand overview while the second section is a step by step guideline on how to develop a customized PSM/RMP program.
The first section of each chapter contains a statement of purpose of the element, an explanation containing a description of the employer’s compliance obligations, a description of relevant OSHA and EPA clarifications, and a list of steps which can be followed to comply with PSM and RMP requirements.
The second section of each chapter contains a sample plan or procedure which can be modified by the employer to produce the relevant compliance documents for inclusion in a PSM and RMP manual. Tips are included to describe suggestions which may be considered when using these plans.
The information in the sample plans is not mandatory and have a range of applicability to various facilities. The applicability and utility of the work practices will depend on many factors such as engineering judgment, the industry standards, the age or size of the facility, the complexity of the process, the size of the system, the size and experience of the workforce and their work practices, and the effectiveness of the engineering and administrative controls.
While the practical benefit of IIAR’s new guidelines to the industry will be enormous, the Institute’s effort in developing them has already strengthened the relationship between the industry and regulators.
Throughout the process of developing the original and most recently, the updated PSM/ RMP guidelines, IIAR has gained the respect of both OSHA and the EPA, said Marrella and Siller. The result of the industry’s effort to respond to PSM/ RMP regulations, to a large extent, has been that both regulatory agencies rely upon recommendations from IIAR in enforcing the programs, they said.
“These agencies are no longer adversaries,” said Siller, “they are partners in improving the safety of systems. That was the ultimate goal…to not just come up with program documentation that filled file folders, but to come up with a program that would improve the safety of our systems.”
Taking a more active role in how the regulations play out in the industry continues to be a driving force behind the work of the PSM/ RMP committee, said Marrella. “The committee worked to produce something that will be useful and relevant, and now that we’ve done that, we’re not hanging up our coats just yet. We’re still looking at ways to expand on the resources available to help companies meet these guidelines. This is just the first step.”
