Smaller Facilities Shouldn’t Overlook Safety Planning

When it comes to safety, prevention is the most important factor in avoiding potential consequences. Whether a facility is working with 900 pounds or 90,000 pounds of ammonia, the risks of an incident are similar.

And although the severity of a potential problem could be smaller with a smaller facility, the risk is still there.

As the industry sees more and more systems built to reduce charge levels, in some cases to get below regulatory thresholds, and in other cases to replace synthetic refrigerants, the question of which guidelines to follow for smaller systems – or those under 10,000 pounds – becomes more and more important.

The refrigeration industry continues to experience an increase in enforcement activities that utilize OSHA’s General Duty Clause, specifically in facilities with less than 10,000 pounds of ammonia, where OSHA expects process safety-like standards to be in place.

IIAR-developed industry safety practices, like the Ammonia Refrigeration Management Program, or ARM, go a long way in protecting the reputation of smaller facilities. The program helps small facilities develop a good safety plan focused on prevention.

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?

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. But nothing could be further from the truth.

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.

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 we continually evolve 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.

The ARM program is a streamlined version of the Institute’s PSM/RMP compliance guidelines. It 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.