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OSHA Process Safety Management (PSM)
As of 1992, all plants with an ammonia inventory of over 10,000 lbs must have had to comply with OSHA's PSM regulation. This regulation which deals with how the plant handles and controls its ammonia system has 14 elements. The elements are:

• Employee Participation
• Process Safety Information (PSI)
• Process Hazard Analysis (PHA)
• Standard Operating Procedures (SOP's)
• Training
• Contractor Requirements
• Pre-start-up Safety Review
• Mechanical Integrity Audits
• Hot Work Permits
• Management of Change
• Incident Investigation
• Emergency Planning and Response
• Compliance Audits
• Trade Secrets

EPA's Risk Management Program (RMP)
As of June 21, 1999, all plants with an ammonia inventory of over 10,000 lbs must submit an RMP plan to the EPA. This plan will remain on file with the EPA and is designed to deal with ammonia potential ammonia releases and how the release effects the surrounding community. Although RMP has some similar aspects to PSM, two differences are:

• An off-site consequence analysis must be performed.
• The RMP plan MUST be submitted to the EPA, registration is required.

Webber/Smith stands ready to assist you in your PSM/RMP needs. Whether you need only a portion of a program, an audit of your current program or the development of an RMP program to compliment your PSM program, we are experienced in the regulations and can develop a program(s) to meet each regulations requirements.

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