Most manufacturers of food or bever- age products have a common con- cern: the need to keep ingredients,
processes and the final product cold. In most
applications, the refrigerant of choice is anhydrous ammonia, but recent changes to OSHA’s
enforcement approach have created new risks
for those food manufacturers who use it.
In 2009, OSHA launched a National
Emphasis Program (NEP) to examine ammonia
management and compliance with the federal
Process Safety Management (PSM) standard.
Initially, this program consisted of enforcement
inspections in three regions of the country. In
2011, it expanded to include all regions. OSHA
has also increased its use of ”recognized and
generally accepted good engineering practice,”
allowing it to bring enforcement action against
facilities that traditionally would not have
been subject to federal and state PSM and
Risk Management Planning (RMP) standards,
including those with less than 10,000 pounds
Increases in inspection frequency and focus
are leading to citations being issued today
where previously they would not have been.
However, there are practical things manufacturers can do to improve their PSM programs.
8 KEY AMMONIA SAFETY
In light of growing regulatory attention,
facilities using anhydrous ammonia should
take these steps to keep safety management
programs up to standard and minimize incident and citation risks:
1. Understand the requirements, cre-
ate a written plan and follow it. Having
proper documentation is essential, but that
alone does not make a successful program.
Implementation is more than half the equation,
and a robust internal training and inspection
process is critical.
2. Incorporate related regulations and
industry standards. The International Institute
of Ammonia Refrigeration, American Society
of Heating and Air-Conditioning Engineers,
American National Standards Institute and
others have regulations and recommendations related to PSM and RMP. Including those
requirements in a PSM and RMP will strengthen them. Related regulatory programs like
Hot Work, Lock Out/Tag Out and Emergency
Planning and Response should also be incorporated.
3. Perform thorough Process Hazard
Assessments and compile complete
Process Safety Information. This includes
analysis of any previous incidents, human
factors involved in processes, facility siting,
maximum intended inventory and more.
Written operating procedures require annual
4. Create, deliver and document appropriate training. Cover all relevant aspects of the
process and operating procedures, and always
document the means used to verify that
employees understand the training.
5. Conduct frequent management of
change analysis and always do pre-startup
safety reviews. These are regulatory require-
ments, and implementing well-written and
compliant procedures will help ensure that
changes to your ammonia refrigeration system
are performed safely.
6. Manage contractors appropriately. There
are many requirements for contractors working on or around ammonia refrigeration systems. Employers must confirm that contractors
are meeting their obligations and following all
7. Be prepared for a visit from OSHA.
Assume they are coming, have a plan and
make sure that management and staff are
equipped to handle an inspection.
8. Bring in the right experts. Some facilities
don’t need outside help to maintain excellent
PSM and RMP programs. But for those who
do, the right partner makes all the difference.
Hire a partner with an understanding of the
engineering and operations challenges of
ammonia management in addition to the regulations and standards.
Not only has the level of scrutiny and
enforcement of ammonia management
changed in recent years, General Duty is
being used much more frequently to justify
significant fines. Inspectors know PSM inside
and out and are looking closely for violations.
Implementation matters now more than ever,
and it is critical that facilities make sure their
programs are fully implemented to avoid incidents and enforcement actions.
Michael J. Curato, P.E., is a Senior Vice
President with Woodard & Curran (www.
woodardcurran.com), with more than three
decades of experience with a wide array of
civil engineering and environmental challenges. He brings a wealth of engineering skill,
process design understanding, and regulatory
knowledge to his work with clients in the
food and beverage industry. His has particular
expertise in Process Safety Management and
Environmental Management Systems. ◆
Safe, Compliant Ammonia
Management Reduces Risk
By Michael J. Curato, P.E., Senior Vice President, Woodard & Curran
Increases in inspection
frequency and focus are
leading to citations being
issued today where previously
they would note have been.