PROCESS SAFETY MANAGEMENT

Process Safety Management (PSM)

OSHA 29 CFR 1910.119 requires the implementation of this program in an attempt to
prevent or minimize the consequences of catastrophic releases of toxic, reactive,
flammable or explosive chemicals.

Ammonia Threshold Quantities: If you exceed the listed threshold quantities of

hazardous materials stored on-site at any given time, then your company is subject to
compliance with this program.

Anhydrous Ammonia = 10,000 lbs

Ammonium Hydroxide = 20,000 lbs (20% NH3 or greater)

R. M. Technologies will complete all written portions of this program in accordance

with applicable regulations; submit the necessary paperwork to the proper governing
agency and aid in the implementation of the program parts.

13 Elements Description
Employee Participation Requires a written plan of action documenting
employee’s involvement in the PSM program.

Process Safety Requires the compilation of written process safety

Information information on process chemicals, process
technology and process equipment.

Process Hazard Requires using a specified process to conduct an

Analysis analysis that contains hazards of the process,
hazardous incident history, engineering and
administrative controls, consequence and effects of
control failure on employees.

Operating Procedures Requires written operating procedures covering

each step of every operating phase, including
operating limits, safety and health considerations
and safety system functions.
Training Training of employees in safety and health hazards,
emergency operations and safe work practices is
required, at the minimum, every three (3) years.

Contractors Requires a written program including procedures to

qualify contractors, a standard package of facility
safety information and procedures to enforce safety
rules and practices.
Pre-Start-Up Safety Mandates a safety review of new facilities and
Review modified sites to confirm integrity of equipment,
assurance that safety, operating, maintenance and
emergency procedures are in place and to verify
that a PHA has been performed.

Mechanical Integrity Requires written procedures documenting a system

to verify the mechanical integrity of process
equipment and dealing with deviations or problems
discovered during the inspection process.

Hot Work Permits Requires written procedures documenting a permit

system for hot work operations in accordance with
National Fire Protection Association (NFPA)
guidelines.

Management Of Change Requires written procedures to assure that system

changes are implemented safely.

Incident Investigation Requires the development of incident investigation

procedures so a proper investigation is conducted
of all incidents that resulted in or could have
resulted in a catastrophic release.

Emergency Planning Requires the development and implementation of a

And Response written emergency action plan or an emergency
response plan in accordance with OSHA 29 CFR
1910.38 guidelines.

Compliance Audits Requires the development and implementation of

an audit program to assure compliance with process
safety requirements every three (3) years.

SAFETY SPECIALIZED SERVICES

R. M. Technologies, Inc. offers specialized services such as, a line of safety equipment
suitable for use with ammonia, various levels of safety training programs and assistance
with required regulatory programs to assure a safe and healthful work environment. Our
commitment to these specialized services will ensure the safe storage, handling and
transportation of ammonia.

Safety Equipment (OSHA 1910.132 – 134)

OSHA requires the use of Personal Protective Equipment when working with or
around ammonia.
Employers are responsible for providing safety equipment to employees to protect the
eyes, face, head and extremities from hazardous contact.
This safety equipment must be kept available, accessible and properly maintained at
all times.
The protective equipment includes: various levels of body protection, eye, face, head,
hand, foot and respiratory protection.

Minimal protection used for nuisance contamination only.

Level D
Chemical Goggles, Face Shield, Rubber Gloves and
Protective Clothing

Protection is worn when the concentrations and types of airborne

Level C substances are known and the criterion for air-purifying respirators
is met.

Rubber Gloves, Chemical Splash Suit, Full Face Cartridge

Respirator and Chemical Boots
The highest level of respiratory protection is necessary but lesser
Level B level of skin protection is needed
Level B Protective Suit, SCBA and Chemical Boots
Protection is required when the greatest level of skin, respiratory
Level A and eye protection is required.
Fully Encapsulated Level A Protective Suit and Chemical
Boots

Safety Training Programs (OSHA 1910.120 & NFPA 472)

OSHA requires all personnel working with or around hazardous materials to be

adequately trained based on their job specific functions.

Awareness For personnel who work around, not directly with, hazardous
Level materials.

First responders at awareness level are expected to recognize

the presence of a hazardous material, protect themselves, call
for trained personnel and secure the area.
Operations For personnel who work directly with hazardous materials.
 Level
Operations level responders are expected to recognize the
presence of a hazardous material, protect themselves while
shutting-down critical operations, if possible, while evacuating
a hazardous material emergency scene, notify emergency
responders, and aid in the securement of the area.
Technician For personnel who have been selected to respond to hazardous
Level material releases/spills.

Technician level responders are individuals who respond to

releases for the purpose of stopping or mitigating them by
trained methods such as plugging or patching.

Regulatory Programs & Training (OSHA 29 CFR 1910.119, EPA Clean Air Act
112(r), & OSHA 1910)

General Industry Safety Requirements

OSHA and EPA require the institution of specific safety programs to prevent the
release of harmful hazardous materials, which could have devastating effects on
company personnel, emergency responders, the general public and the environment.
OSHA requires the implementation of general safety programs to prevent injury and
illness to employees, therefore creating a safe work environment.

RISK MANAGEMENT PLAN

Risk Management Plan (RMP)

EPA Clean Air Act 112(r) requires the implementation of this plan to prevent
accidental releases of regulated substances and to reduce the severity of those releases
that do occur.

Ammonia Threshold Quantities: A process is regulated if a listed substance is present

in amounts greater than it’s threshold quantity.

Anhydrous Ammonia (NH3) = 10,000 lbs

Ammonium Hydroxide (NH4OH) = 20,000 lbs (20% NH3 or greater)

R. M. Technologies will complete all written portions of this program in accordance

with applicable regulations; work with safety personnel to submit the necessary parts of
the program to the proper governing agency and aid in the implementation of the program
parts.

The following is a listing and brief description of the criteria and requirements for
 each of the three programs defined in the RMP program.

PROGRAM CRITERIA REQUIREMENTS

1 No off-site accident history in the Worst-Case Analysis
five (5) years prior to RMP Five (5) Year Accident
submittal date. History
No public receptors in the worst- Certify no additional steps are
case scenario circle. needed
2 Emergency response is Worst-Case Analysis
coordinated with local Alternative Releases
responders. Five (5) Year Accident
The process is not eligible for History
Programs 1 or 3. Document Management
System
Process Safety Information
Process Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigation
Compliance Audit
3 Process is subject to OSHA’s Worst-Case Analysis
PSM program. Alternative Releases
Process is in SIC Code 2611, Five (5) Year Accident
2812, 2819, 2821, 2865, 2869, History
2873, 2879 or 2911. Document Management
System
Process Safety Information
Process Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigation
Compliance Audit

GENERAL INDUSTRY SAFETY

General Industry OSHA Safety Requirements

OSHA mandates the compliance of several General Industry Safety Standards.

R. M. Technologies can provide regulatory assistance and training for several OSHA
programs. Each program will be written and implemented to fully comply with OSHA
program standards.

OSHA OSHA Description

Program Reference
Incident 29 CFR A written program involving incident investigation
Investigation 1910.119 procedures must be completed for the purpose of
investigating accidents, injuries, near misses, releases
and incidents to determine cause and generate
corrective action or prevention methods to eliminate
identified safety hazards.

Blood borne 29 CFR A written program should be implemented that will

Pathogens 1910.1030 focus on reducing the risk of contracting a blood borne
pathogen at your work institution. This program will
include preventative medical procedures and a policy
to evaluate exposure incidents to reduce or eliminate
associated risks.

Safety Program 29 CFR A written plan designed to minimize or eliminate

1910.120, . hazards to employees, the public and the environment
38, .155, . from fires, explosions, unplanned releases and spills of
165 hazardous materials. This program will include
emergency contacts, notification procedures, employee
EPA Sara responsibilities, release reporting procedures, facility
Title III inventory, fire prevention plans, evacuation routes and
part 304 an Emergency Action Plan.

Hazard 29 CFR A written program including procedures for the review

Communication 1910.1200
and organization of Material Safety Data Sheets
(MSDS), creation and maintenance of a hazardous
materials list, implementation of a training program,
procedures for the dissemination of safety and health
information to employees and proper container
labeling procedures.

Lock Out/Tag 29 CFR Written procedures are required for a lock out/tag out
Out 1910.147 program. These procedures are to be in place to
prevent injury or death to employees who perform
maintenance on equipment.

Personal 29 CFR A written program assuring the proper selection and

Protective 1910.132 use of Personal Protective Equipment is to be in place
Equipment to identify what equipment is to be worn and when.
This program must include a hazard assessment of the
 work site and processes identifying the physical and
chemical hazards.

Record keeping 29 CFR OSHA mandates proper record keeping of all injuries
Requirements 1910.1904.1 and illnesses for the purpose of developing
information regarding the causes and prevention of
occupational accidents and illnesses. This information
is collected and analyzed to maintain occupational
safety and health statistics.

Respiratory 29 CFR OSHA mandates a written program covering the

Program 1910.134 hazard assessment, proper selection, use and training
on respirators. This program also requires annual
training, seal and fit tests, passing a pulmonary
function test and medical evaluation.

GENERAL INDUSTRY SAFETY

General Industry OSHA Safety Requirements

OSHA mandates the compliance of several General Industry Safety Standards.

R. M. Technologies can provide regulatory assistance and training for several OSHA
programs. Each program will be written and implemented to fully comply with OSHA
program standards.

OSHA OSHA Description

Program Reference
Incident 29 CFR A written program involving incident investigation
Investigation 1910.119 procedures must be completed for the purpose of
investigating accidents, injuries, near misses, releases
and incidents to determine cause and generate
corrective action or prevention methods to eliminate
identified safety hazards.

Blood borne 29 CFR A written program should be implemented that will

Pathogens 1910.1030 focus on reducing the risk of contracting a blood borne
pathogen at your work institution. This program will
include preventative medical procedures and a policy
to evaluate exposure incidents to reduce or eliminate
associated risks.

Safety Program 29 CFR A written plan designed to minimize or eliminate

 1910.120, . hazards to employees, the public and the environment
38, .155, . from fires, explosions, unplanned releases and spills of
165 hazardous materials. This program will include
emergency contacts, notification procedures, employee
EPA Sara responsibilities, release reporting procedures, facility
Title III inventory, fire prevention plans, evacuation routes and
part 304 an Emergency Action Plan.

Hazard 29 CFR A written program including procedures for the review

Communication 1910.1200
and organization of Material Safety Data Sheets
(MSDS), creation and maintenance of a hazardous
materials list, implementation of a training program,
procedures for the dissemination of safety and health
information to employees and proper container
labeling procedures.

Lock Out/Tag 29 CFR Written procedures are required for a lock out/tag out
Out 1910.147 program. These procedures are to be in place to
prevent injury or death to employees who perform
maintenance on equipment.

Personal 29 CFR A written program assuring the proper selection and

Protective 1910.132 use of Personal Protective Equipment is to be in place
Equipment to identify what equipment is to be worn and when.
This program must include a hazard assessment of the
work site and processes identifying the physical and
chemical hazards.

Record keeping 29 CFR OSHA mandates proper record keeping of all injuries
Requirements 1910.1904.1 and illnesses for the purpose of developing
information regarding the causes and prevention of
occupational accidents and illnesses. This information
is collected and analyzed to maintain occupational
safety and health statistics.

Respiratory 29 CFR OSHA mandates a written program covering the

Program 1910.134 hazard assessment, proper selection, use and training
on respirators. This program also requires annual
training, seal and fit tests, passing a pulmonary
function test and medical evaluation.