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Overview of the Ammonia Refrigeration
Management (ARM) Program
The Ammonia Refrigeration Management (ARM) Program is a voluntary program designed to help
facilities manage their ammonia refrigeration systems in a safe and responsible manner. It is meant
to be used by facilities that operate relatively small ammonia refrigeration systems within industrial
occupancy as defined by the building code and are not covered by the: Occupational Safety and
Health Administration’s (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119);
the Environmental Protection Agency’s (USEPA) Risk Management Program (RMP) Regulation (40
CFR Part 68); or any state-specific PSM or RMP requirements such as in New Jersey, Delaware and
California.
Typically facilities are not subject to PSM and RMP requirements if their ammonia charge
is less than 10,000 lbs. However, facilities are subject to both OSHA and EPA’s General Duty Clause.
OSHA’s General Duty Clause is set forth in section 5(a)(1) of the Occupational Safety and Health Act
(“OSH Act”). It requires an employer to “furnish to each of his employees employment and a place
of employment which are free from recognized hazards that are causing or likely to cause death or
serious physical harm to his employees.” A hazard is “recognized” only if the employer knew that the
particular condition or practice constituted a “recognized hazard,” or that the ammonia refrigeration
industry as a whole recognized that particular condition or practice as hazardous.
Section 112(r)(l) of the Clean Air Act Amendments of 1990 contains the text for USEPA’s General
Duty Clause. USEPA’s General Duty Clause applies to the “owners and operators of stationary
sources producing, processing, handling or storing” regulated substances or other extremely
hazardous substances such as anhydrous ammonia. Facilities subject to the USEPA’s General Duty
Clause have the following three duties:
Identify and assess hazards of releases of extremely hazardous substances
Design and maintain a safe facility to prevent those releases
Minimize the consequences of those releases
The ARM Program is designed to provide facilities the following benefits:
Safety: Ensures that the refrigeration system is not susceptible to damage and to minimize the
number and severity of ammonia-related incidents that could impact employees, community, and/
or environment
Reliability: Improves the operation and efficiency of the ammonia refrigeration system resulting in
less downtime and lower operating costs
Regulatory: Provides documentation that facilities are complying with USEPA’s General Duty
Clause requirements (Section 112(r)(l) of the Clean Air Act) and with the General Duty Clause in
section 5(a)(1) of the Occupational Safety and Health Act (29 U.S.C. § 654(a)(1))