Standard Operating Procedures
The OSHA and EPA regulations require a Standard Operating Procedures element in all PSM/RMP programs.
The purpose of these is to provide clear instructions for the operation of anhydrous ammonia refrigeration systems.
The basics for these programs are two fold: (1) To incorporate some basic elements into the program (often referred to as a ‘technical operating specification’) and (2) to include all the operating phases for operating ammonia refrigeration equipment.
The basic elements should include:
1. Identifying safety and health information regarding anhydrous ammonia
2. Identify the safety features for each equipment type
3. Identify the operating limits for each equipment type
4. Identify the required operating phases for each equipment element
As noted above, items 2 and 3 above are often referred to as a ‘technical operating specification’
The regulation requires that the following operating phases be included in each procedure:
1. Initial Startup
2. Norman Operations
3. Temporary Operations
4. Emergency Shutdown
5. Emergency Operations
6. Normal Shutdown
7. Startup following an emergency shutdown
It should be noted that not all equipment will require all the elements as, for instance, some equipment has no temporary operation. From experience, CECI recommends any section deemed ‘not applicable’ still be addressed as a section; however, maintaining the text identifying that the information is ‘not applicable’.
In addition to addressing the operation of ammonia equipment, the regulations require procedures for safe work practices, which include:
1. Hot Work
2. Confined Space Entry
4. Ammonia Line Opening Procedures
Operating Procedures must be updated when changes are made and reviewed at least every year. There must be documentation to identify when these annual reviews (as well as any revision due to system change) occurred. Failure to document these reviews and changes will can result in fines.
For further information regarding standard operating procedures and/or other PSM related questions, please contact CECI.