By Chris Savage
Most of us in the ammonia refrigeration world are aware of the OSHA and EPA compliance guidelines. You are familiar with PSM (Process Safety Management) by OSHA and the RMP (Risk Management Plan) by the EPA. These 2 programs are very similar, with only a few minor differences. But the intention of both is to keep everyone safe by providing a framework of good practices.
My intention with this blog is not to go into all of the details of these programs, but to mention one of the major components of both programs, and that is the Hazard Analysis.
A Hazard Analysis is very simply just that. Analyzing a system to identify Hazards. There are a variety of different methods for completing one of these, but again, I don’t want to go into all of those details. There are others who are significantly more competent in doing so.
IIAR recently announced that they were contacted by the EPA, “IIAR has received notice from the EPA and several end-users that one area of their focus is determining whether facilities using hazardous chemicals have conducted a hazard analysis.” Most ammonia refrigeration system owners, especially those with over 10,000 lbs (threshold quantity for Anhydrous Ammonia) of ammonia in their system are well aware of this requirement and have a hazard analysis in place and regularly review/update it.
If you are unsure, take this opportunity to ask some questions. Do you have a hazard analysis? When was the last time it was reviewed and updated? How much ammonia is in your system? Do you need a full PSM/RMP program? What are you doing to make sure your system is as safe as it can be?
Most of this conversation revolves around ammonia refrigeration. I would suggest that a hazard analysis applies to any refrigeration system, no matter what size. The hazard analysis is simply a way to take an intentional approach to mitigating potential safety issues. Such a hazard analysis can take many forms and can look different for every system.