This article originally appeared in Food Manufacturing's November/December 2014 print edition.
Most manufacturers of food or beverage products have a common concern: 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 of ammonia.
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 best practices
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, create 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 certification.
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 requirements, 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 applicable rules.
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.
About the Author
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.