Keeping Things Cool: Anhydrous Ammonia Safety

Keeping Things Cool: Anhydrous Ammonia Safety

If you manufacture food or beverage products, you almost certainly need to keep ingredients, processes, and your final product cold. That means serious refrigeration capacity for larger facilities, and in most applications, the refrigerant of choice is anhydrous ammonia.

Anhydrous ammonia is regulated by the Occupational Health and Safety Administration (OSHA) and the U.S. Environmental Protection Agency (EPA), as well as some state programs including the California Accidental Release Prevention (CalARP) Program and New York City’s Risk Management Program. Specifically, facilities with more than 10,000 pounds of anhydrous ammonia have been subject to federal and state Process Safety Management (PSM) standards and the Risk Management Planning (RMP) standards since the 1990s. Recently, OSHA has stepped up enforcement of the PSM standard at regulated facilties.

OSHA National Emphasis Program shines a spotlight on anhydrous ammonia safety

In 2009, OSHA launched a pilot National Emphasis Program (NEP) to look closely at ammonia management and compliance with the federal PSM standard. The pilot program consisted of PSM enforcement inspections in certain regions and emphasized implementation over documentation. In 2011, the NEP was expanded to all regions, with a continued focus on anhydrous ammonia.

The inspections focus on a variety of issues, ranging from employee participation and knowledge of PSM, management of change (MOC) implementation, ventilation and safety system design, mechanical integrity issues such as corrosion under insulation and nondestructive testing of piping, written standard operating and maintenance procedures, and many more.

There has also been an increase in the use of the “general duty clause” to bring enforcement action against facilities with less than 10,000 pounds of ammonia which have experienced a release, fire, employee injury or complaint. In one case, an owner entered a final Consent Order and agreed to pay a substantial fine after a release. The facility had less than 10,000 pounds of anhydrous ammonia in its refrigeration system, but was found to have failed, per General Duty, to identify hazards, design and maintain a safe facility, and minimize the consequences of potential releases.

Ammonia management best practices

With the increased regulatory focus on ammonia, there are a series of steps every facility should take to keep its anhydrous ammonia safety management program up to standard and minimize the risk of incidents and enforcement action.

Understand all the requirements, have a written plan, and follow it. Having the 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.

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, guidelines, and recommendations related to PSM and RMP. Including the requirements of these related industry standards in your PSM and RMP is important and will strengthen them. There are also related regulatory programs like Hot Work, Lock Out/Tag Out, Emergency Planning and Response, and more that must be incorporated.

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. PSI must be updated as often as necessary, and written operating procedures require annual certification.

Give appropriate training and document it. Training must cover all relevant aspects of the process and operating procedures, and documentation must include the means used to verify that employees have understood it. Remember that there are recurring requirements around training (e,g. training must be performed every time a operating or maintenance procedure changes, as new hazards are brought into the work place, etc.).

Conduct frequent management of change analysis and always do pre-startup safety reviews. The regulations require a written Management of Change procedure, which must be implemented under specific conditions. Pre-startup safety reviews are an essential element of Management of Change. Management of Change and Pre-Startup Safety Reviews are regulatory requirements, and implementation of well written and compliant procedures helps ensure that changes to your ammonia refrigeration system are performed safely.

Manage contractors properly. There are many requirements for contractors working on or around ammonia refrigeration systems. Employers are required to confirm that contractors are up to speed on their obligations and are following all applicable rules.

Be prepared for an OSHA inspection and your tri-annual audits. Assume that a visit is coming, have a plan, and make sure that management and staff are equipped to handle an inspection.

Bring in the right experts. Some facilities need no outside help to create, implement, and maintain excellent PSM and RMP programs. But for those who do need support, the right partner makes all the difference. Look for a consultant who has an understanding of the engineering and operations challenges of ammonia management as well as the regulations and standards.

The level of scrutiny and enforcement of ammonia management has changed dramatically in recent years. General Duty is being used much more frequently after the fact and to help justify significant fines. Inspectors know PSM inside and out, and are looking closer and deeper. Having the right documentation is essential, but it is not everything – implementation matters. Facilities need to make sure their programs are fully implemented to avoid incidents and enforcement actions.

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