UPDATED 8/17/14
Routinely we hear the argument that Anhydrous Ammonia should not be on OSHA’s or EPA’s chemical lists for PSM/RMP inclusion. Like most industries that use a single highly hazardous chemical as a “utility” in their process(es) v.s. manufacturing the HHC or using the HHC in the manufacturing process, these industries feel “their chemical” is “safe” and no one should have any concerns. So a client recently challenged me to find any data that would justify a heightened level of concern for a process containing anhydrous ammonia. Unfortunately, it took me only five minutes to win the bet and now the client clearly understands my “radical PSM views” towards his Anhydrous Ammonia. The data I used was…