Industrial

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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  

Table of Contents

Foreword

            How do I use this book?

            What are my responsibilities?

            What if I am Facility Management?

            What if I am a Manager?

            What if I am an Operator?

            What if I am a Human Resources Manager?

            Can I build an Ammonia refrigeration PSM program from this book?

            What if I don’t have the budget or authority to get this accomplished?

 

Process Safety Management History                                                          Page 1

            What is Process Safety Management?

            What is the History of Process Safety Management?

            What are some of these failures?

            What regulations came out of these failures?

            What is a covered process?

            Doesn’t this seem excessive for such a commonly used chemical such as Ammonia?

            Could such a thing happen here?

            Reference: OSHA’s 29CFR1910.119 – Process Safety Management

            Reference: EPA’s 40CFR68 – Risk Management Plan / Program

  

Ammonia is our Highly Hazardous Chemical                                          Page 47

            What is Anhydrous Ammonia?

            What are some of the benefits of Ammonia?

            How dangerous is Ammonia to living things?

            What harm can Ammonia cause to living things?

            Are there any other safety considerations with Ammonia?

            Are there some other things I should know about Ammonia?

            Why do we use Ammonia as a refrigerant?

            What if we have a release of Ammonia?

Are there any warning labels or signs that let us know that Ammonia could be present in an area?

How do we reap the benefits Ammonia offers while managing the risks?

Reference: Ammonia Pressure / Temperature Saturation Chart

 

What is our General Duty?                                                                          Page 57

            What do we mean by General Duty?

            What is the EPA’s General Duty requirement?

            What is the OSHA’s General Duty requirement?

            How does this affect PSM/RMP?

            How do we deal with the General Duty clauses if we don’t already have PSM or RMP?

            Why doesn’t GCAP recommend ARM programs or other simplified versions of PSM?

How do I meet my General Duty, or even PSM, if I am a small facility that contracts out all my refrigeration operation and maintenance duties?

How do most citations for General Duty come about?

 

DHS CFATS and EPA’s Tier II                                                                   Page 65

            What is CFATS?

            What training will be required?

            What steps do I need to take to fulfill this DHS CFATS requirement?

            What is Tier II?

            How do I know if I am covered by EPCRA?

The EPA’s Risk Management Program                                                               Page 71

            What is the EPA’s Risk Management Plan?

            What are Program Levels?

            What is a Public Receptor?

            What are the differences between Program 1 and Program 3?

            How do I calculate a Worst-Case or Alternate Scenario?

            What is a five year accident history?

            What is the “Management System” requirement?

            Are there any requirements for public communication?

            What else does this regulation require?

            How often must I file an RMP?

How do I file the RMP?

Is there a good way to ensure we meet all these RMP regulatory requirements?

Example: RMP Guidelines

Example: Management System Documentation

OSHA’s Process Safety Management Program                                        Page 93

            What is OSHA’s Process Safety Management Program?

            What is in the Employee Participation Element?

            What is in the Process Safety Information Element?

            What is a Process Hazard Analysis?

What is in the Mechanical Integrity Element?

What is in the Operating Procedures Element?

What is in the Employee Training Element?

What is in the Management of Change Element?

What is in the Pre-Startup Safety Review Element?

What is in the Incident Investigation Element?

What is in the Contractors Element?

What is in the Mechanical Integrity Element?

What is in the Compliance Audit Element?

What is in the Emergency Planning and Response Element?

What is in the Hot Work Permit Element?

What is in the Trade Secrets Element?

Designing a Unified Program                                                                     Page 101

            What do we mean by a Unified Program?

Compliance Assurance                                                                                 Page 107

            What types of external regulatory inspections are there?

            What is the Level 3 Risk Management Plan Checklist about?

            What is the Program Quality Verification inspection about?

            How does the CHEMNEP inspection work?

            What do OSHA and EPA citations look like?

            What do the different “types” of violations mean?

            What should we learn from the documents presented in this chapter?

            What if I had a policy but the employee didn’t follow it?

Employee Participation                                                                                Page 123

            What is in the Employee Participation element?

            What does the Employee Participation element require?

            Who are “employees” for the purposes of this element?

            What about the employees who operate, maintain and analyze the process?

            How do most citations in this element come about?

            Employee Participation interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

Example: Employee Participation Guidelines

Example: EP-1 Form – PSM Consultation

            Example: EP-2 Form – PSM Communication and Training Handout

Additional sources of information on the companion CD, Internet and in print

Process Safety Information                                                                          Page 141

            What is in the Process Safety Information element?

            What does the Process Safety Information element require?

            What about “Information pertaining to the chemical”?

            What about “Information pertaining to the technology of the process”?

-          Block Flow

-          Process Chemistry

-          Maximum Intended Inventory

-          Safe Upper and Lower Limits

What about “Information pertaining to the equipment in the process”?

-          Materials of construction

-          Piping and Instrumentation Diagrams

-          Electrical Classification

-          Relief & Ventilation Design

-          Design Codes and Standards employed

            How to I organize all this and control access to it?

            Who is responsible for all this information?

            What are these “Letters to File” you keep referencing?

            How do most citations in this element come about?

            Process Safety Information interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

Example: Process Safety Information Guidelines    

Example: Process Chemistry Letter

            Example: Electrical Classification Letter

Example: RAGAGEP Certification Letter

Example: Material and Energy Balance Letter

            Additional sources of information on the companion CD, Internet and in print

           

Process Hazard Analysis                                                                              Page 177

            What is in the Process Hazard Analysis element?

            How do I perform a Process Hazard Analysis?

            How do I select a methodology?

            How do I select a team?

Management has chosen a methodology and we’ve prepared a team; now how do we perform the PHA itself?

How do I report and track findings?

How often do I have to perform a PHA?

How do most citations in this element come about?

            Process Hazard Analysis interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

Example: Process Hazard Analysis Guidelines

Additional sources of information on the companion CD, Internet and in print

 

Operating Procedures                                                                                            Page 201

            What is in the Operating Procedures element?

            What is meant by Operating Phases in this element?

            How do I organize all these required procedures?

            What does this format include?

            What is in the Document Information section?

            What is in the Equipment Information section?

            What is in the Task Flow / Table of Contents section?

            What is in the Procedure/Policy section?

            What is in the Valve Legend section?

            What is in the P&ID cut section?

            Are there any other requirements?

How do most citations in this element come about?

            Operating Procedures interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

            Example: Operating Procedures Guidelines

Example: ROSOP 101 – Overall System Operation SOP

            Example: RESOP 01 – Operation of Evaporative Condenser #1 SOP

            Example: DOC-CERT – Revision tracking document

                        Additional sources of information on the companion CD, Internet and in print

Training                                                                                                          Page 245

            What is in the Employee training element?

            Who is covered in this Training element?

            What does “to the extent they can affect the process” mean?

            What should this training accomplish?

            How do I train the people who are NOT operating the process?

            How do I train the people who are actually operating the process?

            How often must this training be conducted?

            How do I properly document this training?

            Are there any national consensus standards for operator training?

How do most citations in this element come about?

            Training interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

            Example: Training  Guidelines

Example: Form OT-1 Operator Training Certification Form

Example: Training Needs Assessment

            Additional sources of information on the companion CD, Internet and in print

Contractors                                                                                                     Page 269

            What is in the Contractors element?

            What Contractors are covered under this element?

            What is required by the Contractor element?

            How can I possibly document all of that?

            How does this work in practice?

            Do the CQ forms take care of all the documentation?

How do most citations in this element come about?

            Contractor interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

Example: Contractor Guidelines

Example: CQ-1 Form – Qualifications and Reference

Example: CQ-2 Form – Contractor Safety Communications

Example: CQ-3 Form – Training Record

Example: CQ-4 Form – Evaluation and Approval

Example: CQ-5 Form – Contractor Completion Closeout

Example: CQ-6 Form – Contractor Evaluation

Additional sources of information on the companion CD, Internet and in print

Mechanical Integrity                                                                                     Page 295

            What is in the Mechanical Integrity element?

What equipment is covered in the Mechanical Integrity element?

What do I need to do for each piece of equipment?

Documenting the Inspections, Tests and Maintenance

Correcting Equipment Deficiencies

Are there any other requirements?

What are some things I can do to aid my compliance efforts?

What are some good sources for Best Practices?

How do most citations in this element come about?

            Mechanical Integrity interaction Matrix

            OSHA’s PSM regulation pertaining to this element

            EPA’s RMP regulation pertaining to this element

Example: Mechanical Integrity Guidelines

Example: Form MI-EL1 – Equipment List and MI Schedule

Example: System Walk-Through Form

Example: System Walk-Through SOP

Additional sources of information on the companion CD, Internet and in print

 

Hot Work Permit                                                                                           Page 331

            What is in the Hot Work Permit element?

            I already have a hot work program – do I need to do anything special under PSM?

            I do not have a hot work program – what should I do?

How important are Hot Work permits?

How do most citations in this element come about?

            Hot Work Permit interaction Matrix

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Example: Hot Work Guidelines

Additional sources of information on the companion CD, Internet and in print

Management of Change                                                                              Page 345

            What is in the Management of Change element?

            What is “Change” in this element?

            What is required in this MOC element?

            Management of Change flowchart

            How should I document a “replacement in kind”?

Are there any other types of changes that can be made that aren’t generally done through a Management of Change procedure?

How should I document a “management of change”?

How does this work in the real world?

How can I handle “initial startup” or commissioning?

How do I handle very large changes?

Are there any additional considerations for Temporary Changes?

How should I handle a change that is to People, Procedures and Policies?

What if I discover a change has occurred without a MOC?

Why is this element generally considered the “hardest” to work with?

The “change” being considered doesn’t have any safety and health impacts. Do I still need to perform a MOC?

How long must I retain the MOC documentation?

How do most citations in this element come about?

            Management of Change interaction Matrix

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Example: Management of Change Guidelines

Example: MOC 1 Form – MOC Documentation

Additional sources of information on the companion CD, Internet and in print

Pre-Startup Safety Review                                                                           Page 389

            What is in the Pre-Startup Safety Review element?

            What is required in the PSSR?

            How should I document a PSSR?

            What kind of information should I obtain?

How do most citations in this element come about?

            Management of Change interaction Matrix

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Additional sources of information on the companion CD, Internet and in print

Incident Investigation                                                                                            Page 399

            What is in the Incident Investigation element?

Why should I investigate all near misses and process interruptions if I am not legally required to?

What is required of the investigation?

If there is no “right way” to document an investigation what are the example forms for?

What am I looking for in an incident investigation?

How do I conduct an incident investigation?

What about very minor upsets and near-misses?

What does a good recommendation look like?

Does every incident we investigate require us to re-file our 5-year accident history with the EPA?

How do most citations in this element come about?

            Incident Investigation interaction Matrix

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Example: Incident Investigation Guidelines

Example: II-Short – Incident Investigation Short Form

Additional sources of information on the companion CD, Internet and in print

Emergency Planning and Response                                                           Page 423

            What is in the Emergency Planning and Response element?

            What is required by the EPA portion of this Element?

            What is required by the OSHA portion of this Element?

            How do I handle Incidental Releases?

            How do I comply with Emergency Response / Hazwoper?

How do most citations in this element come about?

            Emergency Planning and Response interaction Matrix

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Example: Emergency Planning Guidelines

Additional sources of information on the companion CD, Internet and in print

Compliance Audits                                                                                       Page 439

            What is in the Compliance Audits element?

            What is required by the Compliance Audit Element?

            How can I perform an audit?

            What becomes of the recommendations?

            How does a regulatory audit differ?

            How can I be prepared for an audit?

If we do internal audits (whether they are compliance audits or not) can OSHA use them against us?

How do most citations in this element come about?

            Compliance Audits interaction Matrix

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Example: Compliance Audit Guidelines

Additional sources of information on the companion CD, Internet and in print

Trade Secrets                                                                                                  Page 455

            What is in the Trade Secrets element?

Since nearly all Ammonia refrigeration systems do not have Trade Secrets, how do we address this?

How do most citations in this element come about?

            OSHA’s PSM regulation pertaining to this element

EPA’s RMP regulation pertaining to this element

Example: Trade Secrets Guidelines

Additional sources of information on the companion CD, Internet and in print

Common Acronyms and Definitions                                                          Page 463

Closing Thoughts                                                                                          Page 479

            What if I have a better idea?

            How can I ever manage to pull all of this together?

 

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edited 8/13