Fertilizer Canada has gotten serious about Facility Siting for NH3 Ag facilities!

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…

The minimum distances from occupancies for siting an anhydrous ammonia storage and handling operation (see below for definition) certified under the Ammonia Code of Practice on or after January 1, 2011 are:

1. 1. 1.5 kilometres (0.93 miles) from the border of a city, town, village or hamlet, or from evacuation-sensitive facilities such as hospitals, schools, residential developments or senior citizens homes; and 
   2. 500 metres (546 yards) from any occupancy (e.g. a rural residence or a small business); and 
   3. 50 metres (54 yards) from an environmentally sensitive area (lake, stream, wetland etc.); and 
   4. Approval from the local authority having jurisdiction is also required.

Compliance will be indicated by documentation such as dated plans demonstrating the required distances, and local authority approval documentation.
The recommended best practice is to locate new anhydrous ammonia storage and handling operations a minimum of 3.0 kilometres (1.86 miles) from the boundary of a city, town, village, hamlet or evacuation-sensitive facilities.

*Anhydrous Ammonia Equipment Storage Operations are defined as an area where anhydrous ammonia vessels, with a combined aggregate volume greater than 10,000 liters (2,641 gallons), are stored for a period greater than 72 hours. Storage areas where all the vessels have been emptied and de-pressured will be exempt from inclusion in this definition.

The code goes on to require the following for businesses within these zones:

To ensure that members of the public located near ammonia operations are adequately informed and aware of emergency procedure, the following measures are required: 

1. 1. Annual contact with people within 3.0 kilometres (1.86 miles):
   1. 1. Communication must inform people of the presence of an ammonia operation, and the communication process to be used in the event of an emergency.
      2. Communication shall be in writing.
      3. Compliance will be indicated by inspection of the list of local stakeholders and dated copies of the required written materials.
   1. Annual contact with people within 1.5 kilometres (0.93 miles):
   1. 1. Communication must include information on the nature and hazards of ammonia.
      2. Communication must include information on basic emergency response procedures including contact numbers, and both shelter-in-place and evacuation procedures.
      3. Compliance will be indicated by inspection of the list of local stakeholders and dated copies of the required written materials.
   1. Review of emergency response plan with people within 500 metres (546 yards):
   1. 1. Local people within 500 metres must be invited annually to a review session of the emergency response plan as it applies to those people.
      2. Compliance will be indicated by inspection of a list of the local people and dated invitation letters to the review sessions.

So Canada seems to be moving in the correct direction with MANDATORY CERTIFICATION for facilities wishing to handle and store NH3.  Although these requirements are NOT enforceable by Canadian Authorities, the program seems to have some built-in checks and balances to ensure all NH3 ag facilities are participating in the program.