OSHA Ammonia PSM Questions

OSHA ammonia PSM questions for 2021 have been released for VPP sites. OSHA’s VPP (Voluntary Protection Programs) recognize employers and workers in industry who have implemented effective safety and health programs and maintain injury and illness rates below nation statistics for their industry. To participate employers must submit an application and address the questions in this document known as Supplement A. Once submitted and the process continues OSHA will undergo a rigorous onsite evaluation. VPP participants are re-evaluated every three to five years to remain in the program.

If your facility is already a VPP, congratulations! Just a friendly reminder that your questions for self-evaluation of calendar year 2021 are dure March 1, 2022. Over the last several years OSHA has sent these questions out to VPP PSM sites. If you’re not, that is okay and as well VPP may not be what you or your company desires. However, it will not hurt to look at the questions being asked and evaluate your sites process safety programs.

We have numerous PSM/RMP and CalARP classes scheduled for 2022 and to view these dates and locations visit this link.

Questions based upon Leading Indicators and Mechanical Integrity

Do you have ammonia-based processes?
How many Mechanical Integrity inspections were scheduled for 2021?
- What percentage of the Mechanical Integrity inspections were delayed beyond the assigned completion date?
Do you collect data on the completions of safety critical PMs for all of your process equipment?
Do you identify all the equipment critical to the safety of your process regardless of the coverage of the Mechanical Integrity program?
Do you have a system in place you use to detect, manager, and report deficiencies in a single piece of equipment?
Number of PM activities were scheduled for 2021?
- What percentage of all your site’s PM was completed for 2021?
What percentage of corrective maintenance work orders were overdue on December 31, 2021?
Does your site have any pieces of critical equipment with projected lifetimes?
- Do you have a metric that tracks the projected lifetime of critical equipment?
Does your training tracking system identify the numbers of trainings planned vs. those completed?
What percentage of employees did NOT complete all required training in 2021? (Examples of training related to PSM, general safety, and emergency procedures)

Questions based upon PSM Metrics and Other

Do you use the same set of PSM metrics to collect information on every system/process that you have at your site?
Do you collect process-based metrics that vary depending on the process?
What percent of PSM metrics that you collect are leading indicators?
Percentage of PSM near miss incidents that resulted in a loss of containment and/or a fire?
Percentage of PSM near miss incidents that could have resulted in a loss of containment and/or a fire?
Percent of near miss or hazard reports that resulted in changes made to equipment, process, and or training?
Do you a process in place for employees to report a job stress or fatigue?
Did you have a VPP on-site evaluation conducted in 2021?
- How many PSM recommendations were identified by the evaluation team?
- How many of these recommendations are still open?
What criteria do you use to determine when you would call in outside emergency response entities during a release (of any quantity) or a fire (of any size)?

Questions based upon Management of Change and Process Hazard Analysis

What percentage of the MOCs conducted during 2021 were emergency MOCs?
What percentage of temporary MOCs put in place in 2021 were extended beyond their original assessed time period for the change?
How many PHAs were performed in 2021?
How many PHA action items were identified as due for completion in 2021?
What percentage of PHA action items scheduled to be closed remained open at the end of calendar year 2021?
How many PHAs were performed in 2020?
How many PHA action items were identified as due for completion in 2020?
What percentage of PHA action items scheduled to be closed remained open at the end of calendar year 2020?

OSHA Ammonia PSM Questions based upon Resident Contractors

Do you have a process in place to report near miss incidents to the host employer?
Do you participate in all of the host employer’s emergency drills?
Do you conduct separate emergency drills/exercise, other than those required by the host?
Do you track specific incidents involving property damage at the host employers site?
- What percentage of that damage was caused by flooding or extreme weather conditions?
Are you aware, at all times, of the specific location of your employees working within the Host’s processes?
Does the host employer have a process in place to identify the location of your employees working within the host’s process?
Who performs site-specific training of the resident contractor employees related to the hazards associated with the hazards of the process chemicals?

OSHA Ammonia PSM Questions based upon Ammonia Refrigeration

Do your employees perform routine inspecting, testing, and preventive maintenance on your ammonia refrigeration system?
Do you have a resident contractor perform routine testing and maintenance of your ammonia refrigeration system?
Do you track the percentage of critical equipment tested verses the percentage of critical equipment scheduled for testing?
Number of thickness measurements collected for the ammonia system pressure vessels and piping equipment in 2021?
- Percentage of measurements resulted in need for corrective action?

Even though VPP participants are exempt from OSHA programmed inspections while they maintain their VPP status doesn’t mean they are not in the grind day in day out living process safety continuously improving their programs, closing out recommendations, and driving process safety to both the leaders above them and the employees who work in and around the systems. What is your program doing to keep it in the pipes?