2016 will go down as the year OSHA and EPA tried to revamp their PSM and RMP rules for handling Highly Hazardous Chemicals (HHC) and Extremely Hazardous Substances (EHS). We have even seen Congress get into the act of blocking OSHA from enforcing PSM on fertilizer distributors. All the while, our friends to the north have been busy implementing their “Fertilizer Canada Anhydrous Ammonia Code of Practice” which go into effect January 2017. Fertilizer Canada is an industry association representing Canadian manufacturers, wholesalers and retail distributors of nitrogen, phosphate and potash fertilizer used in the production of agricultural crops. And this group of companies has developed a “certification” in which ONLY facilities certified as compliant with Fertilizer Canada’s Ammonia Code of Practice (Code) are eligible to receive shipments of anhydrous ammonia. If situations exist where “uncertified facilities” are receiving product or facilities are not in compliance with the Code, a third party complaint process exists to report, investigate and take remedial action. Compliance with the Code may also be randomly verified by Fertilizer Canada through the Quality Assurance/Quality Control program where an auditor may be sent to a certified site to verify compliance at any point during the certification period. The frequency for auditing is every two years (730 days). But it is some of the “facility siting” elements that caught my eye during a visit…