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GCAP’s
Ammonia PSM/RMP Competencies
Prerequisite:
NONE
“Implementing
Process Safety Management for Ammonia Refrigeration”
All
of this material is covered or introduced to the student at our
seminar. This selection of material will allow success in
company’s regulatory requirements.
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
Call us for a free video on PSM/RMP Awareness
Contact
us for more info
Garden City Ammonia Program
2405 E.
Fulton
Plaza
Garden City
,
KS
67846
620-271-0037
620-271-0484 FAX
ammonia@pld.com
www.AmmoniaTraining.com
www.BoilerLicense.com
www.GcapCoolCast.com
edited 3/12 |
