On the most basic level, can a PSM/RMP program function and comply with all regulatory requirements and NOT have a calibrated direct-reading instrument?
This is not meant to be a trick question, but rather looking to “ground me” in my expectations. Having grown up in the PSM/RMP era in petrochem for 20 years, having a calibrated direct-reading instrument available was like having my hardhat and safety glasses available. I do not think a day went by where I did not personally rely on a portable gas detector. In fact, several of my plants we were REQUIRED to wear a detector at all times while signed into the unit. But the $64M question is…
- are they REQUIRED to meet 100% compliance in a process like “refrigeration” where the HHC/EHS is anhydrous ammonia?
- Can a business that has a refrigeration process using NH3 be in full compliance with 1910 standards (with an exception to 1910.146 as they do NOT enter PRCS’s) if they do not have a calibrated direct-reading instrument?
Think about emergency response, homework (although I can see the lack of need for an LEL detector with NH3, seeing how the LEL is 160,000 ppm!), respiratory protection usages, etc.
- If you have one and it broke and the business said they were not going to replace it, where would your Ammonia PSM program fall out of compliance with 1910.119?
- Am I expecting too much to require a facility that processes/stores/handles over 10,000 pounds of NH3 to have a portable direct-reading instrument?
- If you have one and it broke and the business said they were not going to replace it, where would your Ammonia PSM program fall out of compliance with 1910.119? (Remember this business does not enter PRCSs)