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Are Next-Generation Refrigerants Covered by OSHA's Process Safety Management Regulation?

ABS Group Safety, Risk and Compliance Services

Are Your Next-Generation Refrigerants Covered by OSHA's Process Safety Management Regulation?

Hydrofluoroolefins (HFOs) are increasingly being used as next-generation refrigerants in automotive as well as other industries. This new class of refrigerants was introduced to help industry comply with stricter global regulations requiring greater use of nonozone-depleting, low global warming materials.

Given the properties of these materials, companies should conduct appropriate risk assessments and review the potential applicability of the U.S. Occupational Safety and Health Administration (OSHA) process safety management (PSM) regulation 29 CFR 1910.119 (and other similar regulations) to minimize and manage associated process safety risks.

HFO Characteristics and Risks

The OSHA PSM regulation helps companies assess and manage process safety risks associated with handling large quantities of hazardous chemicals. Specifically, the regulation is intended to prevent or minimize the consequences of catastrophic releases of flammable, explosive, toxic, or reactive chemicals by implementing ongoing management systems (elements) such as process hazard analysis, management of change, incident investigation, and mechanical integrity.

As compared with existing nonflammable refrigerants such as HFC-134a, the new HFO refrigerants are flammable gases and, if stored or used in quantities above 10,000 pounds, are likely covered under the PSM regulation. OSHA considers a process covered by PSM if it involves a Category 1 flammable gas [as defined in 1910.1200(c)] or a flammable liquid with a flashpoint below 100 degrees Fahrenheit (37.8 degrees Celsius) on site in one location in a quantity of 10,000 pounds or more.

For example, based on the safety data sheet for HFO-1234yf, HFOs may be covered under the PSM regulation for one or more of the following reasons:

  • The NFPA Flammability rating is 4, indicating that it will readily burn at ambient temperatures
  • The Globally Harmonized System classification is a Category 1 flammable gas with recommended labeling hazard statements of "extremely flammable gas" and "contains gas under pressure; may explode if heated"
  • The flammability range is shown as 6.2-12.3 percent (V) in air with an auto-ignition temperature of 761 degrees Fahrenheit (405 degrees Celsius)

In addition, associated health effects should be considered in risk assessments:

  • The NFPA Health rating is 3, indicating that a short-term exposure could cause serious injury
  • The time-weighted average exposure limit is 500 parts per million (ppm) with the potential for cardiac effects

Adding HFO Refrigerants to Your PSM Program

If HFO refrigerants are being stored or used in a process above OSHA's threshold limit of 10,000 pounds, a facility may be required to add them to existing PSM programs (or implement a new PSM program if no current program exists) in order to assess and manage potential process safety risks.

ABS Group has more PSM experience, both domestically and internationally, than any other firm providing services in these areas. Our engineers are experts at developing and implementing PSM programs using our proven three-phase PSM approach. We recognize that each company has different operational and functional requirements and we tailor programs to suit each client's unique needs. ABS Group consistently (1) delivers robust PSM programs that satisfy regulatory requirements and suit each company's organizational culture and (2) uses model written programs for all OSHA PSM elements. Currently, we are assisting automotive and other industries in conducting PSM gap analyses/audits, PSM training and implementing process safety programs for their use of HFOs.

To request more information or learn more about how ABS Group can help can add value while helping your company achieve its process safety and risk management objectives, contact our PSM experts.

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