OSHA Process Safety Management (PSM) / EPA Risk Management Planning (RMP) Programs
Most of our clients utilize the natural, non-ozone depleting, environmentally friendly refrigerant, ammonia. When the system design requires more than 10,000 pounds of ammonia charge, both OSHA and the EPA get interested. At this threshold, both agencies require preparedness plans known as OSHA’s PSM (Process Safety Management) and the EPA’s RMP (Risk Management Plan). We actively assist our clients with their regulatory needs for both of these programs. Whether your needs are for something as simple as a compliance audit or as complex as the development of full programs, we can help. And we don’t develop the program in a vacuum and then dump it on your lap. We strive to involve you, the owner, in the program development because it is your program and you must know how to work with it and understand it after the project is complete. Let us know how we can help you in your understanding of these complex programs.
Mechanical Integrity Audits
Because we daily design ammonia refrigeration systems for our clients, we are intimately familiar with the RAGAGEP (Recognized And Generally Accepted Good Engineering Practice) and Code/standard requirements. So when we look at your ammonia system integrity, we are looking at it as if OSHA were looking at it. Our final report on your ammonia system will keep you safer.
Not only does OSHA want to know if you’re maintaining your PSM program, but so do we. Our every-three-year compliance audit helps to keep you on track with maintaining your PSM program. We spend time at your site reviewing your program documentation, interviewing your personnel involved in the PSM program and speaking with your contractor that maintains your system. You will benefit from the detail we provide in our Compliance Audit Report.
OSHA PHA (Process Hazard Analysis) and PHA Revalidations
Whether you have an existing PHA (Process Hazard Analysis) that needs revalidated or you need an initial PHA for your new process, we can help in your compliance. We conduct a very detailed and thorough PHA that takes into account the many variables of your ammonia process. The outcome of the PHA process is a list of recommendations to make your ammonia process safer.
Risk Management Plans (RMP)
For ammonia systems over the 10,000 lb. threshold, the EPA requires that you submit a Risk Management Plan. Although this plan is similar in many ways to your OSHA PSM program, there are unique differences. Two of those more important differences are the requirements to model a Worst-Case and Alternate Case release scenario and to register with the EPA on their CDX (Central Data Exchange) website. We regularly help our clients with this process.