GCAP’s Ammonia PSM/RMP Competencies
Prerequisite: NONE
“Implementing Process Safety Management for Ammonia Refrigeration Systems” 6th Edition
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.
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.
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 20,000 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.
Book 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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