RETA Breeze Jul-Aug 2025

VOLUME 3A

Growing Up “Compliant”

A s I have mentioned previously, I have been around ammonia and process safety management (PSM) since I was a toddler. PSM was always a topic of discussion at our house, and I was creating valve lists before I understood what it was that I was doing. My dad would tell me to highlight globe valves pink, regulators blue, solenoids yellow… you get it. Then, I would color its corre sponding number on a list in the same color. Oddly enough, I think this is a good starting point for newer engineers in the business learning how to compile one. I have always wondered why there are 14 elements to the PSM Standard. I think I would have had more. Let’s face it, process safety information (PSI) is a big element and the “informational foundation” of a great program. I’m always surprised that many facilities treat PSI as check box tasks. In a good program, PSI is being updated all the time. As with all of PSM, your PSI should be living documents and always up-to-date. I believe the integrity of the PSI is main tained by a good Management of Change (MOC) program. In my opinion, every change which results in a change to the PSI, must be managed by a management of change. The Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) tend to agree with me. What makes up PSI? Well, almost every thing but standard operating procedures (SOP). Maybe that’s not exactly right, but it feels that way. A very important thing to remember is that OSHA and EPA wrote the standards to apply across all covered industries. They depend on our industry guidance to take over from there. I think all of the information associated

with the process should be included in the PSI section of your PSM/Risk Management Program (RMP). Don’t play the compliance game and say, “Well, OSHA doesn’t list it, so I don’t need to include it in my PSI or MOC program. But I still need to update it.” Make it easy on yourself by including it in the program and maintaining it with your MOC process. It should include all of the following: Per the PSM/RMP Guidance from Interna tional Institute of Ammonia Regulation (IIAR): (1) Information pertaining to the hazards of the highly hazardous chemicals in the process. This information shall consist of at least the following: (i) Toxicity information; (ii) Permissible exposure limits;

By Sarah Selzer, CARO

Editor’s Note: This volume of the series on compliance will appear in two parts, 3a and 3b.

(iii) Physical data; (iv) Reactivity data; (v) Corrosivity data; (vi) Thermal and chemical stability data; and (vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur. (2) Information pertaining to the technology of the process.

(i) Information concerning the technology of the process shall include at least the following: (A) A block flow diagram or

simplified process flow diagram (see appendix B to this section); (B) Process chemistry; (C) Maximum intended inventory;

30 RETA.com