NRC Call – When is it necessary? When is it a good idea?

Most people involved with Ammonia Refrigeration understand that if we have an unintentional release of ammonia in excess of 100 pounds over a 24hr period, we have to report it to the National Response Center (among others) immediately or face substantial fines. These fines can be very large

Because of this, I’m getting reports that some companies are requiring their employees to report EVERY release, no matter how small. Usually this is in response to a citation at one of their facilities for not reporting a release that was clearly over 100 pounds in a timely manner.

While I’ve long counseled that companies should report EVERY release that the REASONABLY believe is near 100 pounds, I think the idea of reporting nuisance leaks (packing leaks for example) that are CLEARLY below 100 pounds, is unwise and it’s very possible that someone is going to ask: “Why is ABC company having so many leaks?” followed shortly thereafter by “Perhaps we should send a referral to the EPA or OSHA to make sure everything is OK!”

Reporting leaks that clearly are not going to involve a release of 100 pounds over a 24 hour period is just asking for trouble. Companies with these policies should reconsider them.

About Brian Chapin

PSM / RMP Compliance Consultant
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