Ammonia PSM compliance services — all 14 elements, built for your facility
If your ammonia refrigeration system holds 10,000 lb or more, OSHA's Process Safety Management standard applies to you in full. We develop, remediate, audit, and maintain PSM programs for ammonia refrigeration facilities — from the threshold question through every element of 29 CFR 1910.119.
Fourteen elements. Every one is auditable.
OSHA doesn't grade on a curve. Each element of 1910.119 carries its own documentation requirements, and each is independently citable in an inspection.
Employee Participation
1910.119(c)
Process Safety Information
1910.119(d)
Process Hazard Analysis
1910.119(e)
Operating Procedures
1910.119(f)
Training
1910.119(g)
Contractors
1910.119(h)
Pre-Startup Safety Review
1910.119(i)
Mechanical Integrity
1910.119(j)
Hot Work Permit
1910.119(k)
Management of Change
1910.119(l)
Incident Investigation
1910.119(m)
Emergency Planning & Response
1910.119(n)
Compliance Audits
1910.119(o)
Trade Secrets
1910.119(p)
Read the full breakdown: The 14 Elements of OSHA PSM
Wherever your program stands, we meet it there
PSM program development
Gap analysis of your existing program, then development or remediation across all 14 elements — written for how your facility actually operates, not from a generic template.
Learn moreCompliance audits
The triennial audit required by 1910.119(o): all 14 elements, EPA RMP, and RAGAGEP conformance against IIAR standards, with a prioritized remediation roadmap.
Learn moreProcess hazard analysis
HAZOP and What-If facilitation for initial PHAs and five-year revalidations, led by engineers with direct ammonia refrigeration experience.
Learn moreMechanical integrity
Covered equipment lists, inspection intervals per IIAR 6, written ITM procedures, and deficiency management — Element 8, implemented properly.
Learn moreAmmonia inventory determination
The threshold question, answered with component-level calculations at actual operating conditions. The foundation of PSM applicability.
Learn moreEPA RMP consulting
Because nearly every PSM-covered ammonia facility is also RMP-covered — registration, hazard assessment, and five-year resubmissions coordinated with your PSM program.
Learn moreWho needs ammonia PSM compliance
PSM coverage follows the ammonia, not the industry. Cold storage warehouses, food and beverage processors, meat and poultry plants, dairies, breweries, and ice facilities are all covered the moment their refrigeration system holds 10,000 lb of anhydrous ammonia.
Facilities below the threshold aren't off the hook: OSHA's General Duty Clause and EPA's CAA §112(r)(1) still require conformance with recognized industry standards — the same IIAR standards that PSM references as RAGAGEP.
The starting point is always the same question: how much ammonia is actually in your system?
The cost of getting it wrong
Operating a covered process without a PSM program exposes a facility to per-violation penalties that OSHA can classify as willful — and every missing element is a separate violation. Six-figure penalty proposals at ammonia refrigeration facilities are routine outcomes of PSM inspections.
A complete, implemented PSM program costs a fraction of a single contested citation — and unlike a citation, it also makes the facility genuinely safer.
Utah, California, and nationwide
NH3Edge is headquartered in Salt Lake City, Utah, with regular on-site PSM compliance work throughout Utah and California. We serve ammonia refrigeration facilities across the United States — program development and documentation are handled remotely, with on-site visits scheduled for field verification, PHA sessions, and audits.
PSM compliance questions
When does OSHA PSM apply to an ammonia refrigeration facility?
OSHA PSM (29 CFR 1910.119) applies when a process contains 10,000 pounds or more of anhydrous ammonia. For refrigeration systems, the entire interconnected system typically counts as one process — vessels, heat exchangers, and piping. A component-level inventory determination establishes which side of the threshold you are on.
What does a complete PSM program include?
A complete program addresses all 14 elements of 29 CFR 1910.119: employee participation, process safety information, process hazard analysis, operating procedures, training, contractors, pre-startup safety review, mechanical integrity, hot work permits, management of change, incident investigation, emergency planning, compliance audits, and trade secrets. Each element requires written documentation and evidence of implementation.
Can we build the PSM program ourselves?
Yes — the regulation doesn't require a consultant. In practice, most facilities that self-build struggle with the ammonia-specific technical elements: process safety information, relief system documentation, mechanical integrity intervals, and PHA quality. A common approach is to have us develop the technical backbone and train your team to own the ongoing elements.
Do you serve facilities outside Utah?
Yes. NH3Edge is based in Salt Lake City and regularly performs on-site PSM work throughout Utah and California, and serves ammonia refrigeration facilities nationwide. Documentation-phase work is performed remotely.
Start with a gap assessment
Send us what you have — or tell us you're starting from zero. We'll map your program against all 14 elements and give you a clear picture of where you stand.