This article originally appeared in Food Manufacturing’s November/December 2014 print edition . Most manufacturers of food or beverage products have a common concern: the need to keep ingredients, processes and the final product cold. In most applications, the refrigerant of choice is anhydrous ammonia, but recent changes to OSHA’s enforcement approach have created new risks for those food manufacturers who use it.  In 2009, OSHA launched a National Emphasis Program (NEP) to examine ammonia management and compliance with the federal Process Safety Management (PSM) standard. Initially, this program consisted of enforcement inspections in three regions of the country. In 2011, it expanded to include all regions. OSHA has also increased its use of ”recognized and generally accepted good engineering practice,”  allowing it to bring enforcement action against facilities that traditionally would not have been subject to federal and state PSM and Risk Management Planning (RMP) standards, including those with less than 10,000 pounds of ammonia.  Increases in inspection frequency and focus are leading to citations being issued today where previously they would not have been. However, there are practical things manufacturers can do to improve their PSM programs.  8 key ammonia safety best practices In light of growing regulatory attention, facilities using anhydrous ammonia should take these steps to keep safety management programs up to standard and minimize incident and citation risks:  1. Understand the requirements, create a written plan and follow it. Having proper documentation is essential, but that alone does not make a successful program. Implementation is more than half the equation, and a robust internal training and inspection process is critical. 2. Incorporate related regulations and industry standards. The International Institute of Ammonia Refrigeration, American Society of Heating and Air-Conditioning Engineers, American National Standards Institute and others have regulations and recommendations related to PSM and RMP. Including those […]