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Material and Energy Balance and “change to facilities that affect a covered process”

One of the most popular PSM requests I get is for an example of a “change to facilities that affect a covered process”.  In this article, I hope to provide an actual example and how a “change to facilities” can affect an ammonia refrigeration facility.  OSHA’s PSM standard states the following about managing changes… (l)

72 incidents & 1 update (10/11/15)

      Over 12,500 exclusive unsafe acts/conditions and accident/injuries photos and over 1,300 ppt’s & doc’s from more than 2,797 contributors! 2015 Fatality Tracker Electrical 35 (2014 =55) (2013 = 32) (2012 = 68) Forklift/Aerial 46 (2014 = 60) (2013=62) (2012 = 52) Mining* 21 (2014 = 401) (2013=87*) (2012 = 92*) *ONLY developed

Does ammonia need to be removed from evaporative condenser coils for entry into these PRCSs??

7/7/2020 UPDATE: Found the OSHA Case where an evaporator fan motor bracket failed, causing the fan to fall onto the coil(s) and cause a NH3 release 6/30/2020 UPDATE:  See my video of an NH3 Condenser Tube/Coil failure (Hydraulic Expansion) on my YouTube Channel   In 2012 I attempted to convince you that ammonia evaporative condensers

EPA RMP citations @ grocer for delayed reporting of ammonia release, risk management, and emergency planning violations ($110K w/ $180K SEP)

A grocer has settled with EPA for alleged chemical release reporting, risk management, and emergency planning violations at its warehouse facility in Seattle, Washington and will pay EPA a $110,200 penalty. The company will also complete a Supplemental Environmental Project which includes ammonia release detection improvements valued at over $180,000. The facility is a distribution

OSHA’s REVISED Field Operations Manual (FOM ) incorporates “employer safety incentive” programs directly into the inspection process

So many of us can recall the 2012 “Letter to Regional Admins” titled Employer Safety Incentive and Disincentive Policies and Practices where OSHA called out “safety incentive” programs that encourage under reporting of accidents.  Then it was merely a “letter” to regional admin(s).  Now the Field Operations Manual (FOM) has been revised in a manner that

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