Every owner of an industrial ammonia refrigeration plant with more than 500 pounds of ammonia in the United States is required by government regulations to have an action and, or, response plan in place should an emergency event occur.

But determining if those plans satisfy OSHA requirements regarding medical treatment and rescue during an ammonia release is not as blackand-white as one might think.

Every plant is different, with unique needs related to size, staffing, location and the availability of first responders.

Although each industrial plant must address the medical and rescue concerns associated with an emergency, the nature of their response can vary depending on their specific circumstances.

OSHA requires that an Emergency Action Plan, or EAP, contain a detailed set of procedures to be followed by employees performing rescue or medical duties, while the Emergency Response Plan, or ERP, must address medical treatment and first aid.

But how do plant owners make sure they are satisfying these requirements? That’s where the waters become muddied.

The reason for that is that these regulations are more performance-based than prescriptive, which means that the regulation places more emphasis on specifying a performance standard for the desired outcome than on how the outcome will be achieved. Thus, plant owners are left to determine, in many cases, the best approach for their particular circumstances.

So where do they go for help? The IIAR Ammonia Data Book and the Safety Data Sheet both offer information about fire control, first aid and chemical characteristics, but neither is sufficient on its own to satisfy OSHA’s requirements.

“Both are excellent resources that would support what you need to know when putting together an EAP or ERP, but they in no way fully cover the need,” said Gary Smith, president of the Ammonia Safety & Training Institute.

“These books provide specific information about ammonia, the responserelated concerns, the hazards, the risks and the details about first aid. But they don’t lay out a reporting system or an evacuation procedure or even how to set up medical and rescue responsibilities.”

The IIAR recently produced a module and training video package to help solve this problem. Titled “The IIAR Ammonia Refrigeration, Education and Training Program: Making the First 30 Minutes Count,” the package spells out how to set up an Emergency Action Plan, EAP, and an Emergency Response Plan, ERP, to satisfy the requirements of both OSHA and the EPA.

For example, it recommends that procedures be put in place in regard to the performance of rescue and medical duties.

“It could be public safety responders, but that must be arranged,” Smith said. “It can’t just be, oh, they will handle that. You must touch base beforehand and let them know what you’re expecting from them.”

In order to satisfy OSHA requirements regarding medical treatment and first aid, the employer should list the locations of first aid kits and other medical support equipment on site, such as automated external defibrillators.

Such first aid equipment must be checked routinely – recommend weekly – to ensure they are sufficiently stocked.

And there must be at least one employee qualified to administer first aid to injured personnel until medical help arrives.

An accounting of employees certified in first aid and CPR should be listed. A list of key personnel with contact information as well as contact information for local emergency responders, agencies and contractors should be included.

Make sure any external department or agency identified in your plan is prepared to respond as outlined in your plan. A documented teaming agreement is helpful in clarifying who is doing what. Medical, decontamination, and rapid entry rescue policies should be reviewed and practiced during joint-training sessions with fire and medical service providers.

Your emergency plan must include the location of hospitals, medical clinics, or facilities close by to handle emergency medical cases. It’s good to bring the Ammonia Safety Data Sheet and/or the IIAR Ammonia Data Book with a victim of an ammonia injury to the treating medical team, said Smith. Ammonia injuries are rare, skin and eye injuries require an immediate focus on the correct ways of treatment.

The Plant emergency planner should make sure that the local medical providers are prepared to handle ammonia injuries with advanced life support services. The Agency for Toxic Substances & Disease Registry, (ATSDR) provides an excellent reference guide. See “Medical Management Guidelines for Ammonia,” on the Agency’s website.

If an infirmary, clinic, or hospital is not close to your workplace, ensure that onsite employees have adequate training in first aid. The American Red Cross, some insurance providers, local safety councils, fire departments, or other resources may be able to provide this training.

The EAP should detail who will direct rescue operations. It should include a company employee designated as an emergency planner who will work in tandem with first responders.

Further, employees are not required to enter danger zones to attempt a rescue. However, the EAP does require the plant to make arrangements to safely evacuate employees from the danger area; to notify first responders; and to provide first aid and basic decontamination until public safety services are on the scene.

“OSHA is concerned with worker safety in regards to implementing an action or response plan,” Smith added. “Specifically, that means the safety elements that are associated with responders and workers and how they both will be protected in an emergency.”