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As noted at EHS Today, the new OSHA initiative came in the form of a 90-day outreach period which the agency says is “an opportunity for employers to proactively seek compliance assistance to ensure they are adequately protecting workers.”
The key materials in the spotlight are fertilizer-grade ammonium nitrate (FGAN) and agricultural anhydrous ammonium. The effort is known as an ‘REP’, or a Regional Emphasis Program, and includes seven states – Arkansas, Kansas, Louisiana, Missouri, Nebraska, Oklahoma, and Texas. But, of course, the regulations and practices being highlighted are part of CFR 1910.109, which covers explosives and blasting agents, and are applicable to all states.
Following three months of compliance assistance, OSHA began stricter enforcement of 1910.109. This step began with inspections of fertilizer storage facilities. And while OSHA sees this program as an enforcement effort directed toward the farming industry, any business that makes use of FGAN and anhydrous ammonia would be wise to review their practices regarding storage, use, and distribution of these substances.
Just the fact that these substances are classified in the same category as blasting caps and small-arms ammunition should tell us a lot about the dangers that are inherent to such materials. But explosivity is only one of the dangers, and how the substance has been processed for use is a key factor in its risks. Pure ammonium nitrate (AN) is, as described in the EPA document Safe Storage, Handling, and Management of Ammonium Nitrate, “stable at ambient temperature and pressure [and] under many conditions, the chemical itself does not burn.” However, the mixture of AN with other materials changes the amount of risk, as does the breakdown of the chemical. Decomposition of FGAN releases toxic gases. Such decomposition usually takes place in extreme heat, perhaps as the result of a fire or an industrial process that produces temperatures in excess of 337 degrees Fahrenheit. So, if FGAN were inappropriately stored near any kind of furnace or oven, the atmosphere in that space could become toxic, to the point of being classified as IDLH (Immediately Dangerous to Life and Health).
Anhydrous ammonia (AA) is now thought of as a security risk as much as it is an immediately dangerous substance. According to the CDC, “Anhydrous ammonia is also a key ingredient in the production of methamphetamine (meth), an illicit activity frequently occurring in makeshift laboratories. Because states require a license for purchase of anhydrous ammonia, those involved in illicit production of meth often resort to stealing it from areas where it is stored and used (e.g., farms, industrial refrigeration systems, and railroad tanker cars).” Thefts of this nature can be the cause of substance releases, too, when plugs are removed by the culprits and not replaced, or valves left open after siphoning.
Findlay All Hazards offers a comprehensive training approach for storers and users of the hazardous substances that are common in agricultural businesses. Findlay project managers have the experience to accurately assess your procedures, identifying any gaps in your compliance and any overt risks to life and property. Are your training methods consistent from location to location? If not, contact Findlay All Hazards today to learn more.