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Joseph and Clint Fabricating

GCAP’s Ammonia PSM/RMP

“Implementing Process Safety Management for Ammonia Refrigeration”

Process Safety Management 

Risk Management Program  

OSHA Compliance Book 29 CFR 1910.119

EPA Compliance Book 40 CFR 68  

PSM/RMP

Introduction:

Too often in the Ammonia refrigeration industry the people tasked with creating and maintaining the Process Safety Management systems that cover our refrigeration systems are simply shown a collection of binders and told “Good Luck”.  Most PSM practitioners we know have suffered this fate at least once in their careers and were nearly overwhelmed trying to make sense of reams of paperwork with little training and even few resources.  GCAP set out to create a book as a guide that could be used as a basis of understanding for each new person “tossed to the wolves” in the PSM realm.

“Implementing Process Safety Management for Ammonia Refrigeration” was written for the exclusive use of Garden City Ammonia Program as a textbook for their Process Safety Management class and to outline a standard of educational material, guidelines, and best practices for the Ammonia industry.  Throughout the years GCAP has met hundred of PSM practitioners and every one left at least one good idea to GCAP.  In some sense, the text presented represents the collected wisdom of those hundreds of PSM practitioners operating thousands of facilities.  GCAP’s focus is on real-world implementation; with due deference given to the practical needs of the facility, the requirements under the regulations and the challenges we face in an increasingly fast-paced and completive business world.

Most of the PSM implementations in our industry rely on the IIAR’s excellent Guide to the Implementation for Process Safety Management for Ammonia Refrigeration first published in 1994, the subsequent Process Safety Management Guidelines in 1998 and its companion Risk Management Guidelines.  While GCAP believes these books provided an excellent resource for their time, PSM implementation has continued to evolve rapidly in the years since they were published and they no longer reflect the “state of the art”.  GCAP’s PSM book is an attempt to re-envision Process Safety Management implementation based on the experiences of the Ammonia refrigeration industry over the past 15+ years.

OSHA’s National Emphasis Program (NEP or CHEMNEP) has served to highlight the deficiencies in the way Process Safety Management for Ammonia refrigeration is currently implemented.  The NEP draws from PSM experience in the chemical process and petroleum refinery sectors, so we have adopted some the ideas and approaches present in the excellent Center of Chemical Process Safety (CCPS) books to improve the system first presented by IIAR considerably.  GCAP believes that the IIAR is still the appropriate source for information regarding the proper design, installation, maintenance, and operation of mechanical Ammonia refrigeration systems; however GCAP turns to the CCPS and other organizations for guidance on how the Process Safety Management programs that cover these systems should be designed and implemented.

GCAP’s book represents the best professional efforts; it should be viewed only as a guideline to implementation; the PSM & RMP regulations, the letters of interpretation form the regulatory agencies and the legal system hold the final say when it comes to compliance.  Process Safety Management Systems must continue to change to meet the challenges presented by evolving regulatory views and Recognized and Generally Accepted Good Engineering Practices (RAGAGEP).  We at GCAP will continue to update our book as a standard reference for implementation of Process Safety Management for Ammonia Refrigeration.

While there are countless people who have contributed to GCAP PSM book, GCAP would like to specifically thank:

Ø       Randy Williams, CEO/Instructor of Garden City Ammonia Program who offered to pay the costs of dozens of Freedom of Information Act requests to receive OSHA PSM Citations, without it would not have been possible to produce the text.  There’s also the 1,000’s of hours he dedicated to staff time in building this book.  Randy was very influential in presenting the contractor’s engineer’s and operator’s point of view throughout the editing process.

Ø       Jeremy Williams, Manager/Instructor of Garden City Ammonia Program who consistently pushes to improve the quality of both the training and the training materials provided by GCAP.  Jeremy’s pursuit of the excellence has been the cause of many rewrites, without which the quality of the works would not be what they are today.

Ø       Brian D. Chapin, Instructor at GCAP who was project leader of the book spent close to 6 months researching, writing, editing, and organizing.  Brian is dedicated to finding elegance in simplicity. 

Ø       Tyler Ramos, Instructor at GCAP who offered keen insights into the unique need of maintenance managers and technicians who are also tasked with PSM implementation. 

Ø       Ammonia Refrigeration Industry, To all the great people who has shared their thoughts, concerns, suggestions, and most of all their expectations of the highest possible quality education and training.

Ø       GCAP Students, Anyone who takes our classes and GCAP teaches us a little bit more about the Art and Science of Ammonia Refrigeration.  Without them, this book would not be possible. 

Ø       OSHA & EPA Compliance Officers, As a rule, consummate professionals of the highest integrity who have dedicated themselves to the safety of employees, the public, and the environment.  While certainly not infallible, the vast majority of the compliance officers we have met have been truly interested in helping Ammonia facilities achieve compliance, not just because it was their job to do so, but also out of a genuine belief that it would help the facility operate their process safely.

We at GCAP thank you for investing your time in our Process Safety Management course.  When you attend a GCAP course you are joining a family of over 8,500 Ammonia professionals throughout the world.  Please always think of the GCAP team as a resource at your disposal when you have any questions about PSM implementation or any Industrial Refrigeration topic.

Your ability to effectively coordinate, your dedication, your talents, and your hard work will be the deciding factors in your PSM implementation.  Process Safety Management is a “Team Sport” and while many teams have star players, everyone’s contribution is invaluable if the team is to reach their goals.  The oft-repeated line “A bad system will beat a good employee every time” is absolutely true when it comes to PSM implementation.  So remember the PSM system you implement in your facility must reflect both the unique needs of that facility and its personnel. 

Process Safety Management 

Risk Management Program  

OSHA Compliance Book 29 CFR 1910.119

EPA Compliance Book 40 CFR 68

GCAP's PSM/RMP “Implementing Process Safety Management for Ammonia Refrigeration”

Chapter A

     A1) What is Process Safety Management?
     A2) PSM Regulation 29CFR1910.119
     A3) RMP Regulation 40CFR68
     A5) HAZWOPER 29CFR1910.120
     A6) PPE 29CFR1910.132
     A7) Respiratory Protection 29CFR1910.134
     A8) Permit Required Confined Spaces 29CFR1910.146
     A9) Lockout/Tagout 29CFR1910.147
     A10) Fire Protection 29CFR1910.155
     A11) Employee Alarm Systems 29CFR1910.165
     A12) Hot Work 29CFR1910.252
     A13) Hazard Communications 29CFR1910.1200

Chapter B

     B1) Why is Ammonia a Highly Hazardous Chemical
     B2) Example Ammonia MSDS
     B3) Ammonia Saturation Chart

Chapter C

     C1) General Duty Clause
     C2) EPA General Duty Fact Sheet
     C3) EPA General Duty Guidance

Chapter D

     D1) DHS's CFATS and EPA's Tier II

Chapter E

     E1) EPA's Risk Management Program and eSubmit of the RMP
     E2) EPA Appendix E
     E3 ) GCAP's Example Hazard Assessment and Scenarios
     E4) GCAP's Management System Example
     E5) GCAP's Risk Management Plan Guidelines example
     E6) GCAP's RMP-Submit Example

Chapter F

     F1) OSHA's Process Safety Management Program
     F2) Appendix C - OSHA's Non Mandatory Guidance

Chapter G

     G1) Design and Implementation of a Unified Program

Chapter H

     H1) Compliance Assurance - PQV vs. NEP
     H2) CPL 2-2.45
     H3) Chemical NEP
     H4) EPA RMP Level 3 Process Checklist

Chapter I

     I1) Process Safety Information
     I2) GCAP's Example PSI Guidelines

Chapter J

     J1) Employee Participation
     J2) GCAP's Example Employee Participation Guidelines
     J3) GCAP's EP-2 PSM Awareness Handout Example

Chapter K

     K1) Process Hazard Analysis
     K2 ) GCAP's Example PHA Guidelines
     K3) GCAP's Example PHA Report
     K4) GCAP's Example PHA Worksheet
     K5) GCAP's Example Recommendation Resolution Spreadsheet

Chapter L

     L1) Mechanical Integrity
     L2) GCAP's Example Mechanical Integrity Guidelines
     L3) GCAP's Example MI-EL1
     L4) GCAP's Example Walk-Through Form
     L5) GCAP's Example Walk-Through SOP

Chapter M

     M1) Operating Procedures
     M2) GCAP's Example Operating Procedures Guideline
     M3) GCAP's Example ROSOP 101 - System Operation
     M4) GCAP's Example ROSOP 113 - Line and Equipment Opening
     M5) GCAP's Example ROSOP 114 - Lockout Tagout Procedure
     M6) GCAP's Example ROSOP 116 -  Personal Protective Equipment
     M7) GCAP's Example ROSOP 117 - Quality Assurance
     M8) GCAP's Example RESOP 01 - Evaporative Condenser
     M9) GCAP's Example DOC-Cert

Chapter N

     N1) Employee Training
     N2) GCAP's Example Operator Training Guideline
     N3) GCAP's Example Operator Training OT-1 Form
     N4) GCAP's Example Training Needs Assessment
     N5) IAR Operator National Standard
     N6) Ammonia Refrigeration Training Guideline (ARTG)
     N7) IIAR ARTG GCAP Cross-Reference
     N8) GCAP's Ammonia MSDS Test
     N9) GCAP's Operator Questions

Chapter O

     O1) Management (Approval) of Change
     O2) GCAP's Example Management of Change Guideline
     O3) GCAP's Example MOC-1 Form
     O4) GCAP's Example MOC-2 Form
     O5) GCAP's Example MOC-3 Form

Chapter P

     P1) Pre-Startup Safety Review
     P2) GCAP's Example MOC-4 Form (PSSR)

Chapter Q

     Q1) Incident Investigation
     Q2) GCAP's Example Incident Investigation Guidelines
     Q3) GCAP's Example IIR-1A Form
     Q4) GCAP's Example IIR-1B Form
     Q5) GCAP's Example IIR-1C Form
     Q6) GCAP's Example IIR-1D Form
     Q7) GCAP's Example IIR-2A Form
     Q8) GCAP's Example IIR-LOG Form
     Q9) GCAP's Example IIR-SHORT Form
     Q10) GCAP's Example IIR-SHORT Form - Forklift Piping Incident
     Q11) GCAP's Example Freeform - Reportable Leak

Chapter R

     R1) Contractors
     R2) GCAP's Example Contractor Guideline
     R3) GCAP's Example CQ-1 Form
     R4) GCAP's Example CQ-2 Form
     R5) GCAP's Example CQ-3 Form
     R6) GCAP's Example CQ-4 Form
     R7) GCAP's Example CQ-5 Form
     R8) GCAP's Example CQ-6 Form

Chapter S

     S1) Compliance Audits
     S2) GCAP's Example Compliance Audit Guideline
     S3) GCAP's Example Combined Audit Form (OSHA & EPA Checklist)

Chapter T

     T1) Emergency Planning and Response
     T2) GCAP's Emergency Planning and Response Guidelines
     T3) Emergency Contingency Plan

Chapter U

     U1) Hot Work
     U2) GCAP's Example Hot Work Guideline

Chapter V

     V1) Trade Secrets
     V2) GCAP's Example Trade Secret Guideline

Chapter W

     W1) Sample Letters to File
     W2) GCAP's Example Process Chemistry Letter
     W3) GCAP's Example Electrical Classification Letter
     W4) GCAP's Example RAGAGEP Certification Letter

Chapter X

     X1) Selected Citations

Chapter Y

     Y1) EPA's Example Accident Prevention and Response Manual

Chapter Z

     Z1) Handouts

Additional:

            Element interaction matrix per element

            17 Pages of Acronyms

            DVD Disk of all forms