Ammonia refrigeration compliance — by someone who knows the system

Every service is grounded in direct ammonia refrigeration experience and current knowledge of OSHA PSM, EPA RMP, and IIAR standards. We don't bring generic process safety consulting to your ammonia plant — we bring ammonia expertise.

OSHA 1910.119EPA 40 CFR 68ANSI/IIAR 2IIAR 9Bull. 110HAZOP
01

Ammonia Inventory Determination

Maximum Intended Inventory Determination

Maximum Intended InventoryEPA 40 CFR Part 68OSHA 29 CFR 1910.119

Your ammonia inventory determines whether you're subject to OSHA PSM and EPA RMP. We perform a complete maximum intended inventory determination — accounting for every component in your system at actual operating conditions.

What You Receive
Component-level charge calculation for all vessels (high-pressure receiver, low-pressure receiver, intercoolers, surge drums, oil pots)
Evaporator charge accounting using coil volume and liquid fill fraction
Condenser charge including flood-back scenarios
All interconnecting piping — liquid lines, suction lines, discharge lines, hot gas lines
Corrected calculations for operating temperature and pressure conditions
Summary table with total system charge and regulatory threshold comparison
Formal report suitable for OSHA and EPA regulatory submissions
Recommendations for threshold management if you're approaching 10,000 lb
Note: Most facilities have never had a proper maximum intended inventory determination. Nameplate charges, general estimates, and simplified calculations frequently undercount by hundreds of pounds.
02

Pressure Relief Valve Analysis

Sizing, Selection & Documentation

Ammonia Relief ValveANSI/IIAR 2-2014IIAR 9ASME Boiler Code

Every ammonia relief valve (pressure relief valve / PRV) on your system must be correctly sized for its specific overpressure scenario. We perform the calculations, verify the installed equipment, and document everything in a PRV register that meets OSHA PSM requirements under 29 CFR 1910.119.

What You Receive
Fire exposure sizing calculations for all vessels with fire risk
Blocked discharge (heat exchanger tube failure) scenarios for applicable vessels
Loss of cooling (condenser failure) scenarios
PRV set pressure verification against MAWP
Discharge piping back-pressure calculations
PRV register with all sizing calculations, relief areas, and set pressures
Identification of undersized, outdated, or incorrectly configured PRVs
Recommendations for corrections with code citations
Note: PRV deficiencies are among the most common findings in OSHA PSM audits of ammonia refrigeration facilities. Incorrect PRV sizing can result in both safety hazards and willful violation citations.
03

Process Hazard Analysis (PHA) Facilitation

HAZOP, What-If & Checklist Methodologies

HAZOPWhat-If Analysis29 CFR 1910.119(e)5-Year Revalidation

OSHA PSM requires a PHA for every covered process, repeated every five years. We facilitate structured hazard identification sessions using the methodology appropriate to your system's complexity — and we produce documentation that survives scrutiny.

What You Receive
PHA scope definition and node development
Full HAZOP or What-If study facilitation with your team
Team composition guidance to meet OSHA requirements
Scenario identification with consequence, likelihood, and safeguard documentation
Formal PHA report with all scenarios, findings, and recommendations
Recommendations prioritized by risk level
Action item tracking and closure documentation
Five-year revalidation scheduling and previous finding verification
Note: OSHA requires the PHA team to include engineers experienced with the process. We bring ammonia refrigeration-specific expertise that generic safety consultants cannot provide.
04

PSM Program Development

All 14 OSHA PSM Elements

All 14 PSM ElementsOSHA 1910.119Program Writing

A complete Process Safety Management program is a substantial body of documentation and operating procedures. We develop or remediate programs across all 14 elements — building programs that reflect how your facility actually operates, not generic templates.

What You Receive
Gap analysis against your current PSM program
Element 1: Employee Participation — plan and implementation
Element 2: Process Safety Information — P&IDs, equipment datasheets, MSDSs
Element 3: Process Hazard Analysis — see PHA service
Element 4: Operating Procedures — startup, normal, emergency, shutdown
Element 5: Training — procedure and records system
Element 6: Contractors — safety program and qualification system
Element 7: Pre-Startup Safety Review — checklist and procedure
Element 8: Mechanical Integrity — see MI service
Element 9: Hot Work Permit — program and forms
Element 10: Management of Change — MOC form and procedure
Element 11: Incident Investigation — procedure and form
Element 12: Emergency Planning — integration with OSHA 1910.38
Element 13: Compliance Audits — schedule and procedure
Element 14: Trade Secrets — written policy
Note: Many facilities have partial PSM programs assembled piecemeal over years. We assess what you have, identify what's missing or inadequate, and build a coherent, complete program.
05

Compliance Audits

OSHA PSM & EPA RMP Audit Readiness

OSHA PSM AuditEPA RMP Review14-Element AuditIIAR Standards

We audit your facility the way OSHA does — systematically, against every element, with documentation reviews and field verifications. You find the gaps first, on your own schedule, before they become citations.

What You Receive
Pre-audit document request list
14-element OSHA PSM audit against 29 CFR 1910.119
EPA RMP compliance review against 40 CFR Part 68
IIAR standard conformance review (IIAR 2, IIAR 9, Bulletin 110)
Field inspection of covered equipment
PRV field verification
Training records review
MOC and incident investigation records review
Written audit report with all findings
Severity classification (administrative, moderate, serious, willful exposure)
Corrective action recommendations with regulatory citations
Prioritized remediation roadmap
Note: OSHA PSM inspections at ammonia refrigeration facilities frequently result in six-figure penalty proposals. Our audit fees are a small fraction of what a single willful citation costs.
06

Mechanical Integrity Program

IIAR Bulletin 110 in Practice

IIAR Bulletin 110PSM Element 8Inspection SchedulingPM Development

Mechanical Integrity is one of the most complex PSM elements to implement correctly. We build MI programs that define what gets inspected, how often, by whom, and what happens when a deficiency is found.

What You Receive
Covered equipment list per OSHA 1910.119(j) requirements
Inspection interval determination based on IIAR Bulletin 110 and manufacturer recommendations
Written inspection and test procedures for each equipment type
Preventive maintenance task list development
Deficiency severity classification criteria
Deficiency tracking system setup
Quality assurance requirements for maintenance work
Contractor qualification for PSM maintenance work
MI program documentation binder
Note: IIAR Bulletin 110 is the RAGAGEP (Recognized and Generally Accepted Good Engineering Practice) for ammonia refrigeration maintenance. OSHA uses it as the standard against which your MI program is measured.

Not sure what you need?

We'll assess your current situation and build a custom scope of work. There's no one-size-fits-all in ammonia refrigeration compliance.