How things have changed in the world of RMP Risks… Anhydrous Ammonia

There are 631 fewer RMP covered processes with Anhydrous Ammonia since 2011.  This translates to a reduction of right at 78 million pounds in anhydrous ammonia in reported RMP covered processes. This took anhydrous ammonia from a clear #1 in pounds in RMP covered processes in 2011 down to #3 in 2017 (see tables below).  What drove such a reduction?  Could it be that OSHA and EPA’s process safety standards are actually having the impact they had hoped for… reducing inventories and thus reducing the severity of a catastrophic release.  It would be interesting to dig deeper and determine what drove such a large reduction in inventories of NH3.  Considering that the “# of facilities” are most likely driven by refrigeration processes and the “pounds in process” are most likely driven by fertilizer facilities with atmospheric cryogenic storage tanks I am guessing that this 78 million pounds reduction could be as simple as 1-2 of these atmospheric cryogenic storage tanks being removed from service.  A quick glance of “deregistered” sites tells us that the vast majority of sites with NH3 as their RMP chemical were fertilizer distributors, but this was NOT a scientific analysis, just merely a scroll down the list and it was very obvious that the fertilizer industry contributed greatly to this reduction.  Why?  Did OSHA’s June 2015 Letter/Memo changing the definition of “retail” have this big of an impact?  Although the courts over-ruled OSHA on the definition of “retail”, was the damage already done?  Anyway you look at it, a reduction of 77,980,065 pounds of any HHC/EHS is a serious reduction in risks.

Here are the Top 10 Chemicals as reported in the RMP Database in 2017 (sorted by pounds):

And here is the same analysis from 2011 (sorted by pounds)