OSHA vs. EPA

Of course, if you are covered under OSHA's PSM regulation you know that you are covered under the EPA's RMP regulation as well. I understand why most people focus on the PSM regulations - they are used to dealing with OSHA regulations that cover everything from PPE to Lockout/Tagout. Furthermore, if you follow the PSM regulations to the letter, you are essentially covering every single element of the RMP requirements but one.

What amazes me is the general lack of interest, or at least the minor importance that is usually placed by most safety professionals on the Risk Management Plan that is unique to the EPA regulations.

Here are the requested budgets for OSHA and the EPA for fiscal year 2009:

OSHA $501.7 million
EPA $7.14 billion

Now that you see the EPA has nearly 14 and a half times the budget, ask yourself a question: Which one of these agencies is more likely to have the resources to make my life miserable?

Please, take some time to review your EPA required Risk Management Plan.

Here are some things to think about:

Is your RMP management system up to date and are those managers keeping up with their responsibilities under the plan? Has this been audited and documented?

Has every incident that could have resulted in a catastrophic release been investigated and documented?

Have you updated your five year accident history?

Has anything happened that would alter the consequences or likely frequency of your catastrophic release scenarios?

Is your currently filed RMP up to date?

Learn Refrigeration Theory

Lets say that you are new to industrial refrigeration, or refrigeration in general. What is the easiest way to get up to speed on this rather counter-intuitive topic?

Well, I read quite a few books on the subject but honestly nothing really clicked for me until I read the RETA 1 & RETA 2 books.

I pick up information fairly quickly and within 30 days of study and application of these texts I was able to troubleshoot about 95% of the industrial refrigeration problems I came across. It turns out that many people who work in industrial refrigeration simply do not understand the theory behind refrigeration.

I've even had long-time operators explain to me that "Theory is fine, but it just doesn't work in the real world." This kind of operator has usually been left to their own devices to limp along a system that just barely works. Worse yet, since they are constantly having to adjust and "fix" the system they are viewed as heroes by many in the organization.

Well, here is the truth: If, in your experience, the theory isn't applicable, then you do not understand the theory well enough.

Buy yourself a copy of the RETA 1&2 books. For a real treat, see which (if any) of your operators can pass the tests that come with the books.

p.s. Avoid the RETA 3&4 books - they are being rewritten and should be updated within the next year or so.

Useful Resources

I'll slowly add to the Useful Resources list on the right over the next few days, but the following are pretty good places to bookmark as a start.

NH3 Info - Air Liquide has an excellent page with all the basic Anhydrous Ammonia properties you will likely ever need.

Refrigeration Engineers NH3 forum - A good place to start for newcomers to ammonia equipment troubleshooting.

Refrigeration Engineers and Technicians Association (RETA) - If you have the opportunity to join your local RETA chapter, I would highly recommend it. They also have a fairly decent online training program for your maintenance personnel.

OSHA's PSM - Occupational Safety and Health Administration's PSM guidance

EPA's RMP - Environmental Protection Agency's RMP guidance.

DHS CSAT - Department of Homeland Security's Chemical Security Anti-Terrorism Standard guidance.

Greetings

I work for a fairly large company implementing a Process Safety Management / Risk Management Program for three Ammonia refrigeration systems.

There are not a whole lot of people who work in this field and I thought that there might be some use in posting the information, strategies, observations and ideas I come across in attempting to create, maintain and implement a successful and compliant PSM/RM program.

If you are not in this field, there isn't much of interest you will find here... Unless of course you have trouble sleeping.