This grocery chain operates six facilities that use ammonia refrigeration processes to provide cooling and freezing to large perishable storage and food manufacturing areas.
These processes contain more than 10,000 pounds (lbs) of anhydrous ammonia. Processes that contain more than 10,000 lbs of anhydrous ammonia are subject to the Occupational Safety and Health Administration's (OSHA) 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (the PSM Standard) and the Environmental Protection Agency's (EPA) 40 CFR Part 68, Chemical Accident Provisions (the RMP Rule). These rules require that subject facilities implement a program and procedures aimed at preventing accidental releases and also require a number of periodic actions such as audits, which must be conducted at least every three years; a process hazard analyses (PHA) which must be completed initially, then updated or revalidated at least once every five years; and RMP Submittals which must be updated and submitted to the EPA at least every five years. The facility PSM Coordinators are responsible for PSM/RMP compliance at their facilities but need assistance with these periodic tasks, agency audits that may occur, and general compliance questions.
Geosyntec's Scope of Services
Geosyntec provides "on-call" PSM/RMP program assistance at the request of facility PSM Coordinators at six locations with ten subject processes. On-call assistance has included site visits to assist locations with preparation for state RMP audits as well as an OSHA PSM audit and assistance at other locations with the completion of audit recommendations and findings. Another task included maintaining documentation related to PSM/RMP compliance on a customized extranet website so that all coordinators as well as Geosyntec representatives may have access to current and historical documentation related to the programs.
PSM and RMP require periodic internal compliance audits at least once every three years. Internal compliance audits for eight of the client's processes were due in 2015. Geosyntec peformed each audit independently and objectively, with minimal participation of the facility PSM Coordinators. Audits included the development of the audit protocol, a review of the written PSM programs, a review of RMP documentation, observations of relevant operations, interviews of facility employees, a review of relevant records, and the preparation of an audit report.
After an initial PHA is completed, a PHA "revalidation" is required at least every five years. Geosyntec provides PHA facilitation services for each of the locations when the PHAs are due for revalidation or a major process change occurs. PHAs are conducting using the What-If/Checklist method and PHAPro® is used to document the PHA discussions.
State RMP audits in 2015 and 2018 included only minor recommendations for compliance improvement with no violations noted.
- Location: Southeast U.S.
- Client: Confidential Supermarket Chain
- Project Practice Areas: Environmental Management
- Type of Facility: Supermarket chain
- Services Provided: Provide annual on-call "Help Desk" assistance related Process Safety Management (PSM) and Risk Management Program (RMP) General Compliance assistance, Conducted periodic internal compliance audits of PSM and RMP Prevention Programs, Provided regulatory audit preparation assistance., Served as revalidation Process Hazard Analysis (PHA) Leader for multiple locations, Served as preparer for RMP Submittal Updates
- Type of Work: Process safety management
- Governing Regulation: OSHA