Develop a PSM ammonia policy

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## 29 CFR 1910 (OSHA) has several similar size gas plants and no sour gas is being processed at the site, then a generic PHA is feasible as long as the variations of the individual sites are accounted for in the PHA. Finally, when an employer has a large continuous process which has several control rooms for different portions of the process such as for a distillation tower and a blending operation, the employer may wish to do each segment separately and then integrate the final results. Additionally, small businesses which are covered by this rule, will often have processes that have less storage volume, less capacity, and less complicated than processes at a large facility. Therefore, OSHA would anticipate that the less complex methodologies would be used to meet the process hazard analysis criteria in the standard. These process hazard analyses can be done in less time and with a few people being involved. A less complex process generally means that less data, P&IDs, and process information is needed to perform a process hazard analysis. Many small businesses have processes that are not unique, such as cold storage lockers or water treatment facilities. Where employer associations have a number of members with such facilities, a generic PHA, evolved from a checklist or what-if questions, could be developed and used by each employer effectively to reflect his/her particular process; this would simplify compliance for them. When the employer has a number of processes which require a PHA, the employer must set up a priority system of which PHAs to conduct first. A preliminary or gross hazard analysis may be useful in prioritizing the processes that the employer has determined are subject to coverage by the process safety management standard. Consideration should first be given to those processes with the potential of adversely affecting the largest number of employees. This prioritizing should consider the potential severity of a chemical release, the number…

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Division 2 AO 3-2019 - (i) Appurtenances - All devices such as pumps, compressors, safety relief devices, liquid-level gaging devices, valves and pressure gages. - (ii) Cylinder - A container of 1,000 pounds of water capacity or less constructed in accordance with Department of Transportation specifications. - (iii) Code - The Boiler and Pressure Vessel Code, Section VIII, Unfired Pressure Vessels of the American Society of Mechanical Engineers (ASME) - 1968. - (iv) Container - Includes all vessels, tanks, cylinders, or spheres used for transportation, storage, or application of anhydrous ammonia. - (v) DOT - U.S. Department of Transportation. - (vi) Design pressure is identical to the term 'Maximum Allowable Working Pressure' used in the Code. - (vii) Farm vehicle (implement of husbandry) - A vehicle for use on a farm on which is mounted a container of not over 1,200 gallons water capacity. - (viii) Filling density - the percent ratio of the weight of the gas in a container to the weight of water at 60 degrees F. that the container will hold. - (ix) Gas - Anhydrous ammonia in either the gaseous or liquefied state. - (x) Gas mask - Gas masks must be approved by the National Institute for Occupational Safety and Health (NIOSH) under 42 CFR part 84 for use with anhydrous ammonia. - (xi) Capacity - Total volume of the container in standard U.S. gallons. - (xii) DOT specifications - Regulations of the Department of Transportation published in 49 CFR Chapter I. - (b) Basic rules. This paragraph applies to all paragraphs of this section unless otherwise noted. - (1) Approval of equipment and systems. Each appurtenance shall be approved in accordance with paragraph (b)(1)(i), (ii), (iii), or (iv) of this section. - (i) It was installed before February 8, 1973, and was approved, tested, and installed in accordance with either the provisions of the American National Standard for the Storage and Handling of Anhydrous Ammonia, K61.1, or the Fertilizer Institute Standards for…

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## 29 CFR 1910 (OSHA) needs to follow to obtain the necessary clearance to get the job started. The work authorization procedures need to reference and coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry procedures and hot work authorizations. This procedure also needs to provide clear steps to follow once the job is completed in order to provide closure for those that need to know the job is now completed and equipment can be returned to normal. - 11. Managing Change. To properly manage changes to process chemicals, technology, equipment and facilities, one must define what is meant by change. In this process safety management standard, change includes all modifications to equipment, procedures, raw materials and processing conditions other than 'replacement in kind'. These changes need to be properly managed by identifying and reviewing them prior to implementation of the change. For example, the operating procedures contain the operating parameters (pressure limits, temperature ranges, flow rates, etc.) and the importance of operating within these limits. While the operator must have the flexibility to maintain safe operation within the established parameters, any operation outside of these parameters requires review and approval by a written management of change procedure. Management of change covers such as changes in process technology and changes to equipment and instrumentation. Changes in process technology can result from changes in production rates, raw materials, experimentation, equipment unavailability, new equipment, new product development, change in catalyst and changes in operating conditions to improve yield or quality. Equipment changes include among others change in materials of construction, equipment specifications, piping pre-arrangements, experimental equipment, computer program revisions and changes in alarms and interlocks. Employers need to establish means and methods to detect both tech…

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Division 2 AO 3-2019 Oregon Administrative Rules Oregon Occupational Safety and Health Division - (ii) Horizontal above ground containers shall be so mounted on foundations as to permit expansion and contraction. Every container shall be supported to prevent the concentration of excessive loads on the supporting portion of the shell. That portion of the container in contact with foundations or saddles shall be protected against corrosion. - (iii) Containers installed underground shall be so placed that the top of the container is below the frost line and in no case less than 2 feet below the surface of the ground. Should ground conditions make compliance with these requirements impracticable, installation shall be made otherwise to prevent physical damage. It will not be necessary to cover the portion of the container to which manhole and other connections are affixed. When necessary to prevent floating, containers shall be securely anchored or weighted. - (iv) Underground containers shall be set on a firm foundation (firm earth may be used) and surrounded with earth or sand well tamped in place. The container, prior to being placed underground, shall be given a corrosion resisting protective coating. The container thus coated shall be so lowered into place as to prevent abrasion or other damage to the coating. - (v) Containers with foundations attached (portable or semi-portable tank containers with suitable steel 'runners' or 'skids' and commonly known in the industry as 'skid tanks') shall be designed and constructed in accordance with paragraph (c)(1) of this section. - (vi) Secure anchorage or adequate pier height shall be provided against container flotation wherever sufficiently high floodwater might occur. - (vii) The distance between underground containers of over 2,000 gallons capacity shall be at least 5 feet. - (6) Protection of appurtenances. - (i) Valves, regulating, gaging, and other appurtenances shall be protected against tampering and physical …

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Division 2 AO 3-2019 Oregon Administrative Rules Oregon Occupational Safety and Health Division - (16) Electrical equipment and wiring. - (i) Electrical equipment and wiring for use in ammonia installations shall be general purpose or weather resistant as appropriate. - (ii) Electrical systems shall be installed and maintained in accordance with Subpart S of this part. - (c) Systems utilizing stationary, nonrefrigerated storage containers. This paragraph applies to stationary, nonrefrigerated storage installations utilizing containers other than those covered in paragraph (e) of this section. Paragraph (b) of this section applies to this paragraph unless otherwise noted. - (1) Design pressure and construction of containers. The minimum design pressure for nonrefrigerated containers shall be 250 p.s.i.g. - (2) Container valves and accessories, filling and discharge connections. - (i) Each filling connection shall be provided with combination back-pressure check valve and excess-flow valve; one double or two single backpressure check valves; or a positive shutoff valve in conjunction with either an internal back-pressure check valve or an internal excess flow valve. - (ii) All liquid and vapor connections to containers except filling pipes, safety relief connections, and liquid-level gaging and pressure gage connections provided with orifices not larger than No. 54 drill size as required in paragraphs (b)(6)(iv) and (v) of this section shall be equipped with excessflow valves. - (iii) Each storage container shall be provided with a pressure gage graduated from 0 to 400 p.s.i. Gages shall be designated for use in ammonia service. - (iv) All containers shall be equipped with vapor return valves. - (3) Safety-relief devices. - (i) Every container shall be provided with one or more safety-relief valves of the spring-loaded or equivalent type in accordance with paragraph (b)(9) of this section.

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## 29 CFR 1910 (OSHA) activities it is quite important that their activities be controlled while they are working on or near a covered process. A permit system or work authorization system for these activities would also be helpful to all affected employers. The use of a work authorization system keeps an employer informed of contract employee activities, and as a benefit the employer will have better coordination and more management control over the work being performed in the process area. A well run and well maintained process where employee safety is fully recognized will benefit all of those who work in the facility whether they be contract employees or employees of the owner. - 8. Pre-Startup Safety. For new processes, the employer will find a PHA helpful in improving the design and construction of the process from a reliability and quality point of view. The safe operation of the new process will be enhanced by making use of the PHA recommendations before final installations are completed. P&IDs are to be completed along with having the operating procedures in place and the operating staff trained to run the process before startup. The initial startup procedures and normal operating procedures need to be fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode for meeting the process parameters. For existing processes that have been shutdown for turnaround, or modification, etc., the employer must assure that any changes other than 'replacement in kind' made to the process during shutdown go through the management of change procedures. P&IDs will need to be updated as necessary, as well as operating procedures and instructions. If the changes made to the process during shutdown are significant and impact the training program, then operating personnel as well as employees engaged in routine and nonroutine work in the process area may need some refresher or additional training in light of the chan…

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Division 2 AO 3-2019 Oregon Administrative Rules Oregon Occupational Safety and Health Division - (iv) Safety-relief valves shall be so arranged that the possibility of tampering will be minimized. If the pressure setting adjustment is external, the relief valves shall be provided with means for sealing the adjustment. - (v) Shutoff valves shall not be installed between the safety-relief valves and the container; except, that a shutoff valve may be used where the arrangement of this valve is such as always to afford full required capacity flow through the relief valves. - (vi) Safety-relief valves shall have direct communication with the vapor space of the container. - (vii) Each container safety-relief valve used with systems covered by paragraphs (c), (f), (g), and (h) of this section shall be plainly and permanently marked with the symbol 'NH3' or 'AA;' with the pressure in pounds-per-square-inch gage at which the valve is set to start-todischarge; with the actual rate of discharge of the valve at its full open position in cubic feet per minute of air at 60 degrees F. and atmospheric pressure; and with the manufacturer's name and catalog number. - Example: 'NH3 250 4050 Air' indicates that the valve is suitable for use on an anhydrous ammonia container, is set to start-to-discharge at a pressure of 250 p.s.i.g., and that its rate of discharge at full open position (Subdivisions (ii) and (iii) of this subparagraph) is 4,050 cubic feet per minute of air. - (viii) The flow capacity of the relief valve shall not be restricted by any connection to it on either the upstream or downstream side. - (ix) A hydrostatic relief valve shall be installed between each pair of valves in the liquid ammonia piping or hose where liquid may be trapped so as to relieve into the atmosphere at a safe location. ## (10) General. - (i) (Reserved) - (ii) Stationary storage installations must have at least two suitable gas masks in readily-accessible locations. Full-face masks with amm…

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Division 2 AO 3-2019 Oregon Administrative Rules Oregon Occupational Safety and Health Division - While OSHA believes process safety management will have a positive effect on the safety of employees in workplaces and also offers other potential benefits to employers (increased productivity), smaller businesses which may have limited resources available to them at this time, might consider alternative avenues of decreasing the risks associated with highly hazardous chemicals at their workplaces. One method which might be considered is the reduction in the inventory of the highly hazardous chemical. This reduction in inventory will result in a reduction of the risk or potential for a catastrophic incident. Also, employers including small employers may be able to establish more efficient inventory control by reducing the quantities of highly hazardous chemicals on site below the established threshold quantities. This reduction can be accomplished by ordering smaller shipments and maintaining the minimum inventory necessary for efficient and safe operation. When reduced inventory is not feasible, then the employer might consider dispersing inventory to several locations on site. Dispersing storage into locations where a release in one location will not cause a release in another location is a practical method to also reduce the risk or potential for catastrophic incidents. - 2. Employee Involvement in Process Safety Management. Section 304 of the Clean Air Act Amendments states that employers are to consult with their employees and their representatives regarding the employers efforts in the development and implementation of the process safety management program elements and hazard assessments. Section 304 also requires employers to train and educate their employees and to inform affected employees of the findings from incident investigations required by the process safety management program. Many employers, under their safety and health programs, have already esta…

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## 29 CFR 1910 (OSHA) If the employer wants specific employees in the release area to control or stop the minor emergency or incidental release, these actions must be planned for in advance and procedures developed and implemented. Preplanning for handling incidental releases for minor emergencies in the process area needs to be done, appropriate equipment for the hazards must be provided, and training conducted for those employees who will perform the emergency work before they respond to handle an actual release. The employer's training program, including the Hazard Communication standard training is to address the training needs for employees who are expected to handle incidental or minor releases. Preplanning for releases that are more serious than incidental releases is another important line of defense to be used by the employer. When a serious release of a highly hazardous chemical occurs, the employer through preplanning will have determined in advance what actions employees are to take. The evacuation of the immediate release area and other areas as necessary would be accomplished under the emergency action plan. If the employer wishes to use plant personnel such as a fire brigade, spill control team, a hazardous materials team, or use employees to render aid to those in the immediate release area and control or mitigate the incident, these actions are covered by §1910.120, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. If outside assistance is necessary, such as through mutual aid agreements between employers or local government emergency response organizations, these emergency responders are also covered by HAZWOPER. The safety and health protections required for emergency responders are the responsibility of their employers and of the onscene incident commander. Responders may be working under very hazardous conditions and therefore the objective is to have them competently led by an on-scene incident commander and the comm…