Process Safety Management

All ammonia refrigeration systems containing 10,000 pounds or more of anhydrous ammonia are required to comply with 29 CFR 1910.119 - OSHA’s Process Safety Management. This includes all currently operating systems with refrigerant charges above the threshold limit. A new refrigeration system must be in compliance when it is initially charged with ammonia. Knowledge of the PSM regulations, along with all the related standards in the OSHA regulations, is paramount in order to have an effective and complete PSM implementation at any facility.
 
Sutton & Associates, Inc. has key personnel with over 30 years of experience in the servicing, installation, operation, and engineering of all types of ammonia refrigeration systems throughout the United States. Sutton & Associates has been involved since the inception of PSM compliance within the industry, completing or supplying major portions of PSM programs for many of the nation’s leading refrigeration-oriented businesses.
 
Sutton & Associates’ professional team has extensive experience with ammonia refrigeration systems, as well as safety putting Sutton & Associates as a leader in OSHA Process Safety Management compliance for ammonia refrigeration systems.

Our PSM Program Includes: 
There are fourteen defined elements of a Process Safety Management (PSM) program. Within some of these elements, extensive information needs to be gathered and engineering calculations need to be performed to verify the design.
 
Our complete PSM program includes:

  • Employee Participation
  • Process Safety Information
  • Process Hazard Analysis (PHA)

Operating Procedures:

  • Training
  • Contractors
  • Pre-Startup Safety Review
  • Mechanical Integrity Audit
  • Hot Work Permit
  • Management of Change
  • Incident Investigation
  • Emergency Planning and Response
  • Compliance Audits
  • Trade Secrets 

Coordination between understanding and applying the regulation for a specific ammonia refrigeration system is critical.
Only with this regulation applied, can: 1. The facility be in compliance with PSM and 2. The facility realize the benefits of the regulation. 
 
General Duty 
This program is developed for facilities that have smaller ammonia refrigeration systems and that contain less than 10,000 pounds of anhydrous ammonia. These facilities are not subject to the OSHA’s Process Safety Management (PSM) Standard (29 CFR 1910.119) or the EPA’s Risk Management Program (40 CFR Part 68) but are subject to their respective General Duty Clauses. 
 
Sutton & Associates will assist in the development of the following elements: 

  • Drawing requirements
  • Refrigeration system documentation
  • Ammonia awareness, safe work practices and notification procedures
  • Training
  • Emergency Planning for an ammonia release
  • Testing and Inspections

Risk Management Plan (RMP) 
The Environmental Protection Agency (EPA) require certain companies to develop and share information about the chemicals used, the potential risks those chemicals pose to the community, the ways a company manages those risks, and in the unlikely event of a release how well prepared to respond. This requirement is part of the EPA’s Risk Management Plan rule.
 
Sutton & Associates provides:
Management Systems….
Assist to develop written system description
Hazard Assessment Development….
Worst case release scenario
Alternate release scenario
Document 5 year accident release history
Prevention Program Development
Risk Management Plan Development
Electronic Filing Procedure
 
 
Other PSM Services Provided: 
PSM Program Support
In addition to a complete PSM, Sutton & Associates can help assist updating any part of your Process Safety Management implementation efforts.
 
Drawings
Sutton & Associates can provide refrigeration Piping and Instrumentation Diagrams (P&IDs) as well as a Simplified Process Block Flow Diagrams and Mass Flow Balance Drawings, as required.
 
Operating Procedures
Sutton & Associates can furnish complete refrigeration equipment Standard Operating Procedures (SOPs) based on manufactures recommendations.
 
Compliance Audits
Informal Audit - Sutton & Associates offers an informal audit of any existing PSM implementation. Sutton & Associates can evaluate your program to determine it’s completeness and effectiveness and also review your records to determine if record-keeping requirements have been met. A report will be prepared with recommendations in time for you to make appropriate changes before the real compliance audit required by OSHA.
Full Compliance Audit - Sutton & Associates can provide the OSHA required three year audit, using the OSHA in-depth auditing procedures.
 
Training
Sutton & Associates can provide OSHA-required training on an initial basis or the required refresher training. Ammonia awareness, Specific ammonia refrigeration system operation and “Hands On” training can be tailored to your needs. All documentation of the training session is provided for your records.
 
Preventive Maintenance Program
A computerized maintenance scheduler can be provided to help maintain the process equipment. Detailed PM Tasks have been developed equipment specific according to manufacturer’s recommendation and facility maintenance personnel recommendations.