Canada has an interesting requirement for their NH3 refrigeration plants that operate within structures where the general public could be exposed to the NH3. Since the promulgation of OSHA’s PSM standards in 1992, OSHA has shied away from even mentioning “staffing” for a covered process. In the USA, we have plants that run 24/7/365 without trained refrigeration personnel on-site, and under the current PSM/RMP regulations, this is permitted [until something goes wrong]. OSHA/EPA can use PHA and SOP matters to enforce staffing, but it is a “round-about,” to say the least. Another interesting matter is that Canada does not base its risk analysis on pounds of NH3 in the process, but rather they use KW of energy used by the process.
PLEASE NOTE that these regulations qualify specific roles to be in charge of a “shift” but not the entire “plant” – a very logical and interesting idea.
Here is a look at how they manage their NH3 refrigeration plants in public occupancies: