Regulations & Standards Alignment

From Requirements to Reliable Execution

Facilities that operate with ammonia or other highly hazardous chemicals are subject to a range of overlapping requirements—federal, state, and industry-driven. Sotera helps clients understand what applies, close gaps, and build programs that hold up in real operations and during regulatory scrutiny.

A Practical, Audit-Ready Approach

Regulatory compliance is only effective if it works in the field. Sotera helps facilities build and maintain programs that are:

Operationally realistic – usable procedures, clear ownership, clean records
Technically defensible – documented rationale, RAGAGEP alignment
Inspection-ready – organized evidence, closed-loop action management
Sustainable – repeatable processes, not “one-and-done” projects

OSHA Process Safety Management (PSM) – 29 CFR 1910.119

OSHA’s PSM standard is designed to prevent catastrophic releases of highly hazardous chemicals by requiring disciplined management systems—not just documentation. Sotera supports compliance across the full PSM lifecycle, including:

Process Safety Information (PSI) development and validation
Process Hazard Analyses (PHAs) and action item management
Mechanical Integrity (MI) program
Operating procedures, training, and contractor safety programs
Management of Change (MOC) and Pre-Startup Safety Reviews (PSSRs)
Compliance audits and ongoing continuous improvement practices

Our approach focuses on building programs that are clear, usable, and sustainable—so teams can maintain compliance and reduce risk year-round.

IIAR Guidance & PSM Program Expectations (Ammonia Refrigeration)

For ammonia refrigeration systems, industry best practices and recognized guidance from IIAR (The International Institute of All-Natural Refrigerants) are often used to inform “what good looks like” for safe design, operation, and maintenance. Sotera helps clients align their PSM programs with IIAR-recommended practices by translating technical expectations into practical program requirements.

OSHA & EPA General Duty Clause support (including facilities below 10,000 lbs)

Even when a system is below a threshold (e.g., under 10,000 lbs of ammonia), facilities can still have obligations under OSHA and EPA General Duty provisions. Sotera helps clients evaluate hazards, align safeguards with recognized practices (RAGAGEP), and maintain documentation that demonstrates responsible risk management.

CalARP (California Accidental Release Prevention) – Title 19 / CCR Requirements

Small-quantity chemicals at facilities including agriculture, pharmaceuticals, metals finishing/coating
Time-dependent recommendation closure
Seismic Assessments that meet local requirements
California Environmental Reporting System (CERS)
Extensive experience collaborating with Certified Unified Program Agencies (CUPAs)
Tailored support for each facility’s specific needs, aligned with the requirements of its governing jurisdiction.