UPDATED on 9/2/12… Is there an OSHA PSM or EPA RMP requirement that liquid ammonia piping/equipment that can trap the liquid be equipped with a proper type and sized releif device or can a “qualified refrigeration technician” take the place of a relief device? This question has been debated within the refrigeration industry PSM/RMP circles for the past 20 years; yet in 2006 OSHA answered this questions quite clearly in a LOI. In this same letter, we begin to see OSHA’s displeasure with the direction some RAGAGEP revisions are going; as they point out, the RAGAGEP may have changed, but the HAZARD HAS NOT!
Question 10: Has OSHA taken a position with regard to the elimination of safety devices based on “trained operators”?