In June 2015, OSHA released a new interpretation of the retail exemption for Process Safety Management (PSM). The interpretation rescinds the retail exemption for facilities handling anhydrous ammonia for sale as fertilizer. This places up to 3,800 facilities that sell anhydrous ammonia under PSM regulations.
The main concern is with the farmers and co-ops that use the product at these affected facilities. According to The Fertilizer Institute, a majority of these operations “did not fully understand what it would take to comply with PSM.” * In addition, the cost to build a PSM program could be prohibitive and resource constrained. The estimated cost for compliance is estimated at “$5,000 to $30,000 to either hire contractors or divert internal resources to comply with PSM.” *
To meet the PSM standard, the retail facilities would need, at minimum, to document:
- Validate Process Safety Information
- Certify pressure vessels per ASME code
- Process Hazard Analysis performed
- Procedures written for all phases of operation
- Training documented for employees in PSM
- Contractors certified to work on PSM covered facilities
The first step is to perform a PSM audit. The audit covers one element of the PSM standard and provides a road map for implementing the other elements. An audit looks at each element in the PSM standard to determine the client’s implementation of those elements.
The PSM audit will allow the client to identify which of their current practices qualify as “PSM practices.” A primary concern with PSM is that it is different from normal safety systems. While some practices may need improvement, well-developed safety programs, management commitment to safety, and a facilities existing RMP program will go a long way to implementing a PSM program.
In addition to a first look PSM audit, a contractor should be able to perform several PSM elements that may be lacking in the same site visit:
- Process Hazard Analysis (PHA)
- Procedure updates, as part of the PHA
- PSI documentation plan
Additional cost savings can be realized by implementing PSM programs across multiple sites. Many retailers operate ammonia-handling systems close to their customers, the farmers. A geographical focus would allow central management of a PSM program that impacts all the operational sites.
According to The Fertilizer Institute/ Agricultural Retailers Association, the availability of contractors certified to work on PSM covered processes in a major constraint for implementing a program: *
- Contractors who are qualified to replace anhydrous ammonia tanks, or make other upgrades to anhydrous ammonia systems are already in tight supply
- Two certified contractors in the entire state of Kansas, the third largest consumer of anhydrous ammonia
- Took more than a year to get a certified contractor onsite to make the upgrades
- Given the demand for upgrades to comply with PSM, these contractors are going to be in even shorter supply
A PSM consultant will take the results of the initial audit and existing programs to develop the timeline necessary to implement the additional requirements the facility faces as part of PSM. The first steps, and the defined framework for full compliance should earn a facility the clarity and financial planning necessary with less concern for enforcement action from OSHA.
Process Safety Management should not be viewed by those facilities handling hazardous chemicals as a regulatory burden. PSM is the gold standard for keeping employees, contractors, and the public safe from high hazardous chemicals. There are many ways to meet the performance standards under PSM. A PSM consultant can provide the best road map to maintain and improve safety practices while meeting the regulations.
PSM is not an additional cost of doing business; it is one of the costs in keeping everyone safe.
All references from joint letter dated September 23, 2015 from The Fertilizer Institute and Agricultural Retailers Association.