Compliance
Independent reviews that show where your program stands and what to fix before an inspector finds it.
- PSM / RMP compliance audits
- IIAR 9 gap analysis for existing systems
- Process Hazard Analysis facilitation and PHA audits
- RAGAGEP reviews
Ammonia Refrigeration PSM & RMP Consulting Services
At Covered Process Consulting, we understand that process safety is more than documentation. With a background in industrial ammonia refrigeration operations, mechanical service, and regulatory compliance, we help facilities develop practical, effective PSM and RMP programs that reflect their actual equipment and operations.
Services
Support for every part of a covered ammonia process, from a single annual inspection to a full program build-out.
Independent reviews that show where your program stands and what to fix before an inspector finds it.
Hands-on inspections by someone who has serviced equipment in the field, with clear findings and recommended actions.
Written programs and process safety information that match how your plant actually runs.
Practical training from a RETA-certified operator who has trained plant crews across multiple facilities.
Drawings and calculations that keep your process safety information accurate and current.
About
We founded Covered Process Consulting after a decade of running and servicing ammonia refrigeration systems. Before consulting, we managed refrigeration operations and PSM compliance across multiple cold storage and production facilities, where we developed SOPs, led PHAs, ran mechanical integrity and management of change programs, oversaw contractors, and trained operators.
That background shapes how CPC works. Recommendations are practical, inspections are thorough, and the paperwork matches what is actually in your facility.
OSHA 29 CFR 1910.119
We can support any of the fourteen elements, whether you need one element fixed or the whole program reviewed. Select an element to read its requirements in the OSHA standard.
(c)Employee Participation↗
(d)Process Safety Information↗
(e)Process Hazard Analysis↗
(f)Operating Procedures↗
(g)Training↗
(h)Contractors↗
(i)Pre-Startup Safety Review↗
(j)Mechanical Integrity↗
(k)Hot Work Permits↗
(l)Management of Change↗
(m)Incident Investigation↗
(n)Emergency Planning & Response↗
(o)Compliance Audits↗
(p)Trade Secrets↗
EPA 40 CFR Part 68
Most ammonia refrigeration facilities above the 10,000-pound threshold are Program 3 processes under the RMP rule. We support each requirement, from the hazard assessment and offsite consequence analysis to your five-year RMP resubmission. Select an element to read its requirements in the regulation, or visit the EPA RMP program page.
§68.15Management System↗
§68.20Hazard Assessment & OCA↗
§68.65Process Safety Information↗
§68.67Process Hazard Analysis↗
§68.69Operating Procedures↗
§68.71Training↗
§68.73Mechanical Integrity↗
§68.75Management of Change↗
§68.77Pre-Startup Review↗
§68.79Compliance Audits↗
§68.81Incident Investigation↗
§68.83Employee Participation↗
§68.85Hot Work Permits↗
§68.87Contractors↗
§68.90Emergency Response↗
§68.150RMP Submission & Updates↗
Below the threshold
Systems that aren't subject to PSM or RMP still carry obligations under OSHA's General Duty Clause (Section 5(a)(1) of the OSH Act) and EPA's General Duty Clause (Clean Air Act Section 112(r)(1)).
We support General Duty Clause facilities the same way we support covered processes: hazard analyses, mechanical integrity inspections, operating procedures, training and emergency planning, all built to recognized and generally accepted good engineering practice, including IIAR 9.
Know your deadlines
The recurring requirements most ammonia facilities need to plan around. If one of these is coming due, we can help you get ahead of it.
| Frequency | Requirement | Reference |
|---|---|---|
| Annually | Mechanical integrity inspections of the refrigeration system and its associated components | ANSI/IIAR 6 |
| Annually | Certify standard operating procedures as current and accurate | 1910.119(f)(3) |
| Every 3 years | PSM compliance audit | 1910.119(o)(1) |
| Every 3 years | RMP compliance audit | 40 CFR 68.79 |
| Every 3 years | Operator refresher training | 1910.119(g)(2) |
| Every 5 years | PHA update and revalidation | 1910.119(e)(6) |
| Every 5 years | RMP update and resubmission | 40 CFR 68.190 |
| Every 5 years | 5-year mechanical integrity inspection | ANSI/IIAR 6 |
| Every 5 years | IIAR 9 minimum safety criteria review | ANSI/IIAR 9 |
Refresher training is required at least every three years, and more often if needed.
Changes to your facility, personnel or processes, including anything handled through Management of Change, can alter these schedules. If you have questions about how a change affects your deadlines, send us a note through the request form.
Need an experienced hand for a PHA, a mechanical integrity audit or field data collection? CPC works as a subcontractor for other PSM firms and fits into your process.
We work directly with the industry's leading PSM software companies and can provide support on all of their platforms. That includes setting up programs, loading process safety information, and keeping mechanical integrity, management of change and compliance records current for your clients.
Are you a PSM software company that would like to be represented here? Please reach out through the contact section below.
We proudly support the R-717 Safety nonprofit organization.
Contact
Tell us about your facility and what you need. We'll follow up within one business day.
Based in Stoughton, Wisconsin. Serving facilities throughout the Midwest and nationwide.